THE U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 


PUBLIC HEALTH SERVICE 


CENTERS FOR DISEASE CONTROL AND PREVENTION 


NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH 


convenes the 


WORKING GROUP MEETING 


ADVISORY BOARD ON 


RADIATION AND WORKER HEALTH 


ROCKY FLATS
 

The verbatim transcript of the Working 


Group Meeting of the Advisory Board on Radiation and 


Worker Health held in Hebron, Kentucky on 


March 28, 2006. 

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 6 

C O N T E N T S
 

March 28, 2006 


WELCOME AND OPENING COMMENTS 


DR. LEWIS WADE, DFO 


TIB 49 14 


SUPER S 68 


SAMPLE DR’S 69 


COMMENT 4 71 


AMERICIUM 241 80 


COMMENT 6, CALIBRATION 88 


PLUTONIUM TETRACHLORIDE CALIBRATION 97 

DATA INTEGRITY 97 


PENETRATING DOSES PRIOR TO 1976 124 


ALGORITHM 125 

COMMENT RESPONSES, MARCH 21, ‘06 129 


MARCH 24TH COMMENTS 240 


COURT REPORTER’S CERTIFICATE 259 

3 

TRANSCRIPT LEGEND
 

The following transcript contains quoted material. Such 


material is reproduced as read or spoken. 


In the following transcript: a dash (--) indicates 


an unintentional or purposeful interruption of a 


sentence. An ellipsis (. . .) indicates halting speech 


or an unfinished sentence in dialogue or omission(s) of 


word(s) when reading written material. 


-- (sic) denotes an incorrect usage or pronunciation 


of a word which is transcribed in its original form as 


reported. 


-- (phonetically) indicates a phonetic spelling of 


the word if no confirmation of the correct spelling is 


available. 


-- "uh-huh" represents an affirmative response, and 


"uh-uh" represents a negative response. 


-- "*" denotes a spelling based on phonetics, 


without reference available. 


-- (inaudible)/ (unintelligible) signifies speaker 


failure, usually failure to use a microphone. 

 

 

 

4

 P A R T I C I P A N T S 


(By Group, in Alphabetical Order) 


BOARD MEMBERS
 

EXECUTIVE SECRETARY
 

WADE, Lewis, Ph.D. 


Senior Science Advisor 


National Institute for Occupational Safety and Health 


Centers for Disease Control and Prevention 


Washington, DC 


MEMBERSHIP
 

GIBSON, Michael H. 


President 


Paper, Allied-Industrial, Chemical, and Energy Union 


Local 5-4200 


Miamisburg, Ohio 


GRIFFON, Mark A. 


President 


Creative Pollution Solutions, Inc. 


Salem, New Hampshire 


MUNN, Wanda I. 


Senior Nuclear Engineer (Retired) 


Richland, Washington 


PRESLEY, Robert W. 


Special Projects Engineer 


BWXT Y12 National Security Complex 


Clinton, Tennessee 

5 

IDENTIFIED PARTICIPANTS
 

ALLEN, DAVE, NIOSH 


BARRIE, TERRIE, ANWAG 


ELLIOTT, LARRY, NIOSH 


FALK, ROGER, ORAU 


FITZGERALD, JOE, SC&A 


GLOVER, SAM, NIOSH 


HARDEN, JERRY 


HOWELL, EMILY, HHS 


JESSEN, KARIN, ORAUT 


KATZ, TED, NIOSH 


KOTSCH, JEFF, DOL 


LANGSTED, JIM, ORAU 


LITTLE, CRAIG, ORAU 


MAKHIJANI, ARJUN, SC&A 


MAURO, JOHN, SC&A 


MEYER, BOB, ORAU 


NETON, JIM, NIOSH 


REID, STEVE, ORAU 


ROBINSON, AL, ORAU 


SMITH, MATTHEW, ORAU 


SUNDIN, DAVE, NIOSH 


THOMPSON, JENNIFER, PETITIONER 


ULSH, BRANT, NIOSH 

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P R O C E E D I N G S


 (10:10 a.m.) 

(Note from the Court Reporter: The following 


transcript contains a great number of 


“unintelligible” messages. Unfortunately 


transcription was often rendered impossible due to 


faulty audio-visual equipment of the meeting facility 


and poor telephonic connections. Please know these 


gaps in transcription are not the fault of the court 


reporter and not the fault of the speakers.) 


WELCOME AND OPENING COMMENTS
 

DR. LEWIS WADE, DFO


 DR. WADE: This is Lew Wade. I’d like to 


welcome the working group, the meeting of the 


working group. This is the working group that 


deals with issues related to site profiles, 


reviews of individual dose reconstructions and 


reviews of procedures. The group is ably 


chaired by Mark Griffon and consists of Mike 


Gibson, Bob Presley and Wanda Munn. All of 


those individuals are with us either by phone 


or around the table in Cincinnati. Let me sort 


of briefly set the table for what we’re doing 


and what will follow based upon what we’re 

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doing. The Board has responsibility, statutory 


responsibility to review individual dose 


reconstructions. To assist them with that 


responsibility the Board has taken on the -- 


the task of reviewing site profiles which are 


documents that dose reconstructions can be 


based upon. The Board has been involved in a 


review of the Rocky Flats site profile for some 


time now. The Board has used its contractor, 


Sanford Cohen and Associates, to assist in the 


review of that site profile. Recently with the 


awareness that there was an SEC petition 


pending on Rocky Flats, this working group and 


the Board has asked that the focus of the site 


profile really for the time being be on issues 


that are related to the SEC petition; but again 


we’re still looking at the subcommittee and its 


work of reviewing site profiles. Once this 


meeting is over some things will happen. NIOSH 


intends to release its petition evaluation 


report on the Rocky Flats SEC petition in the 


first week of April. This working group will 


reconvene on the morning of April 12th and will 


take on the responsibilities of the SEC 


petition. Again much of what we -- we talk 

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about here today will inform and guide those 


discussions but when this group meets again on 


the 12th, its focus will be particularly on the 


SEC petition and the petition evaluation 


report. It is anticipated that the Board will 


debate during its April 25th, 26th and 27th
 

meeting, full Board meeting, the Rocky Flats 


SEC petition and come to some recommendation on 


that petition. So that’s what we’re doing 


here, looking at technical issues in the site 


profile with a particular eye towards the SEC 


petition. And then on the 12th we’ll be 


focused particularly on the SEC petition. 


Well, I’d like to do a couple of things now. 


I’d like to go around and introduce the people 


who are here around the table. I’d like to 


introduce people on the phone starting with 


representatives of the NIOSH or ORAU teams, the 


SC&A teams, obviously the Board members 


present, other federal employees that are 


present on the call, anyone directly involved 


in Rocky Flats; petitioners, members of 


Congress or representatives of those members 


who have an interest; and then anyone else who 


would like to be identified. Then we’ll have a 

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bit of a conflict of interest discussion where 


I’ll talk a little bit about the Board and its 


members relative to Rocky Flats. I would ask 


the leader of the NIOSH delegation to identify 


his team including identifying any conflicts 


that exist. I would ask the leader of the SC&A 


to do the same thing. And then I’ll turn it 


over to Mark and Wanda to begin the 


deliberations. So with that as an action plan 


we’ll start around this table. Again, my name 


is Lew Wade. I work for NIOSH and have the 


privilege of serving as the Designated Federal 


Official for the Advisory Board. 

 MR. LITTLE: My name is Craig Little. I’m with 

the ORAU team. 

 MR. FALK: And my name is Roger Falk. I’m with 

the ORAU team. 

 MR. LANGSTED: Jim Langsted with the ORAU team. 


 MR. MEYER: Bob Meyer with the ORAU team. 


 DR. ULSH: I’m Brant Ulsh with NIOSH. 


 DR. NETON: Jim Neton with NIOSH. 


MR. ALLEN: Dave Allen with NIOSH. 


 DR. GLOVER: Sam Glover with NIOSH. 


 DR. MAKHIJANI: Arjun Makhijani with SC&A. 


 MR. FITZGERALD: Joe Fitzgerald with SC&A. 

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 MR. PRESLEY: Robert Presley with the Board. 


 MS. HOWELL: Emily Howell, HHS. 


 MS. MUNN: Wanda Munn with the Board. 


 DR. MAURO: John Mauro with SC&A. 


 MR. ELLIOTT: Larry Elliott, NIOSH. 


 DR. WADE: Now, before I turn to have members 


on the phone identify themselves, one note from 


Ray. If at all possible, please try and use 


the handset on your phone and not a speaker 


phone. It works much better for us here. If 


anyone has any problems hearing or being heard 


we’ll yell at you, you yell at us. We want to 


make use of all the talent that’s here and on 


the line. Let’s start with members of the 


Board who are on the call. 


 MR. GRIFFON: Mark Griffon. 


 MR. GIBSON: Mike Gibson. 


 DR. WADE: Thank you. Members of the NIOSH and 


ORAU team who are on the phone. 


 MS. JESSEN: Karin Jessen, ORAU team. 


UNIDENTIFIED: Kay (unintelligible), ORAU team. 


UNIDENTIFIED: (Unintelligible), ORAU team. 


 DR. WADE: That last gentleman needs to speak 


louder and more clearly. 


UNIDENTIFIED: (Unintelligible), ORAU team. 

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 MR. ROBINSON: Al Robinson, ORAU team. 


 MR. SMITH: (Unintelligible) Smith, ORAU team. 


 MR. REID: Steve Reid, ORAU team. 


 DR. WADE: Anyone from NIOSH on the call? 


 MR. SUNDIN: This is Dave Sundin, NIOSH. 


 MR. KATZ: Ted Katz, NIOSH. 


 DR. WADE: SC&A team? 


UNIDENTIFIED: (Unintelligible) 


 DR. WADE: Could you speak more clearly, 


please? 


UNIDENTIFIED: Joan (unintelligible). 


 DR. WADE: Okay. Anyone else? 


(No response) 


 DR. WADE: Okay. How about Rocky Flats 


petitioners or interested parties? 


 MS. BARRIE: This is Terri Barrie with ANWAG. 


 DR. WADE: Anyone else representing or of the 


Rocky Flats community? 


(No response) 


DR. WADE: Other federal employees? 


 MR. KOTSCH: Jeff Kotsch, Department of Labor. 


 DR. WADE: Is there anyone else on the call who 


would like to be identified? 


(No response) 


DR. WADE: Okay. Let’s have a bit of a 

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conflict of interest discussion in three parts. 


As it turns out there are no Board members on 


this working group who are conflicted on Rocky 


Flats and therefore there are no prohibitions 


to the full participation of any of the working 


group members either in the discussion on site 


profile or SEC petition. Now, I would ask the 


leader of the NIOSH ORAU team to identify 


members and potential conflicts. 


 DR. ULSH: I’ll handle that, Lew. With regard 


to the ORAU team members present here in the 


room we’ve got Jim Langsted and Roger Falk, 


both of whom have long working histories at 


Rocky Flats. They’re here in the capacity of 


subject matter experts. I am heading up the 


team that’s evaluating the SEC petition that 


was submitted and Karin Jessen is on the phone. 


She is heading up the response to the -- she’s 


preparing our evaluation report. There’s no 


conflict there. I think it’s just Jim and 


Roger, and so they are here in the capacity of 


subject matter experts. 


 DR. WADE: Okay. SC&A? 


 DR. MAURO: Participants here today are myself, 


John Mauro, Joe Fitzgerald, Arjun Makhijani and 

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Dunstana Melo. None of us have a conflict; 


however I would like to ask Joe to just 


summarize briefly his role, one, with DOE, and 


his relationship in that role regarding Rocky 


Flats. 


 MR. FITZGERALD: Yeah. First off, I worked for 


the Department of Energy from 1980 to 2001, 


headed the Health and Safety office of DOE 


headquarters from ’91 to 2001, and was 


basically responsible for all the policies and 


regulations on radiation protection for the 


Department of Energy for that time span. But 


certainly nothing that would be linked to the 


operations of the Rad program at Rocky or any 


of the actual procedures or policies 


implemented at the site. So I don’t -- 


certainly don’t see a conflict of interest. 


 DR. WADE: Okay. I think that brings us to 


starting the deliberations of the meeting. I 


will point out that this is a public meeting 


but we’ve allowed no opportunity for public 


comment. We have, as is our process, allowed 


petitioners to -- to make comment as they feel 


is appropriate and ask questions and make 


contribution. So any of the petitioners or 

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their representatives, you’re allowed to fully 


participate and that’s encouraged. Wanda or 


Mark, please? 


 MR. GRIFFON: Yeah. I think, Wanda, we’re just 


going to stay with the matrix so -- the matrix 


that we had worked from, dated February 27th , 


2006. And I think if it makes sense we’ll just 


do like we did with Y-12, go down the action 


items and work from there. Is that okay, 


Brant? 


 DR. ULSH: Sure. 


TIB 49


 MR. GRIFFON: Okay. So the first one is 


actually probably the most lengthy discussion 


that we’ll get into. Item 1A is the TIB 49. 


 DR. ULSH: We’re in the process of -- 


 MR. GRIFFON: I think you’ve -- you’ve provided 


quite a bit of information on this so I’ll let 


you take it over, Brant. 


 DR. ULSH: We’re in the process of getting the 


handout going around the table here, Mark. 


Just give us a couple of minutes. And actually 


as you mentioned, TIB 49, a draft of it has 


been delivered to SC&A along with a lot of 


supporting material. Jim Neton has been 

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heavily involved with this, and I think he’s 


going to head up the discussion on our approach 


for super S. 


 MR. GRIFFON: Now, what you’re handing out can 


you -- do I have that? Do we have that? 


 DR. NETON: You should have, Mark. That’s 


titled, “An Approach to Dose Reconstruction for 


Super Type S Material,” dated March 21st, 2006. 


 MS. MUNN: Jim sent it out by email. 


 DR. NETON: It went out a few days ago. 


 MR. GRIFFON: Okay. 


 DR. NETON: So I’ll be speaking from two 


documents. One is the draft OTIB 49, a 


document that was sent out awhile ago; I’ve 


forgotten what time. It’s also on the O drive. 


And also what I would call a supplement to OTIB 


49 which is titled, “The Approach to Dose 


Reconstruction for Super Type S Material.” I 


think I’m just going to summarize where we’re 


at with this and just I’ve got a couple control 


dosimetry experts from NIOSH with me to back me 


up on some of these analyses. And I’ll just 


open the floor for discussion. OTIB 49 if you 


looked at it is our approach to correcting for 


the differential solubility of varying 

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solubles, so-called super type S material 


versus what would be normally the ICRP default 


of a soluble material called type S. It’s 


recognized in several places, Rocky Flats among 


them, that there are forms of plutonium that 


just do not behave like type S material. That 


is they -- they leave the lungs much more 


slowly than one would expect. To look at this, 


the difference in the lung dose per -- on a per 


unit intake basis -- that is if I inhaled the 


same amount of type S material and the same 


amount of type super S material, what would be 


the difference in -- in lung dose over time? 


We put a team of experts together to evaluate a 


number of cases. In TIB 49 there were ten 


design cases that were evaluated. Nine of 


those cases were specific to Rocky Flats and 


there was one case that was well documented 


exposure at the Hanford facility. When one 


looked at the retention of plutonium in the 


lungs of those ten design cases, two stood out 


as having very similar clearances and very -- 


and also exhibited the longest retention times 


of any of the ten cases. The two cases are 


Rocky Flats 872 and the so-called Hanford 1 

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case. In the TIB 49 document one looks at the 


clearance of those two cases overlapped on the 


graph. They’re -- They’re virtually identical 


with some exceptions in the very early time 


periods. The decision was made by the expert 


team to use those two cases as bounding 


analyses, that is the most insoluble materials 


to calculate the difference in the lung dose 


over time. So an analysis was done using our 


IMBA software where the case was evaluated 


using the available lung monitoring data and 


the available urinalysis data to fit a 


retention code. Based on those retention codes 


one can calculate then the estimated difference 


in the dose between how the retention in the 


lungs would behave for super S versus S and in 


the analysis since HAN 1 and Rocky Flats 872 


are so close, they chose to create an 


adjustment factor per year based on the case 


that exhibited the highest difference between 


super S and -- and S. So that’s the basis of 


TIB 49, so it really is a look-up table 


document that -- that one would, if I knew the 


intake of type S -- if I knew the intake of 


material, how much more dose would I have to 

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assign to a person because of the lengthy 


clearance of super S from the lungs. That 


takes care of one issue we think. That issue 


is how are the lung doses determined. 


 MR. GRIFFON: I was curious about you said you 


-- you had ten design cases? 


 DR. NETON: Uh-huh. 


 MR. GRIFFON: What was the universe of cases, 


or was that the universe of cases? I don’t 


understand how you -- how you got to these 


cases. Some of them were known from a 


plutonium fire; is that correct? Or --


 DR. NETON: Right. I think Roger Falk, who is 


sitting here, was one of the experts that 


participated in -- in this analysis and I -- I 


can -- the experts are listed on the document. 


They’re Tom LaBone, Roger Falk, and Don Bihl. 


Since Roger’s here maybe he could comment on 


the selection process. 


 MS. MUNN: Roger, turn that mike around. 


 MR. FALK: The cases were chosen based on being 


clean cases. That means that they had no 


significant previous exposures to the -- to the 


one major exposure that gave them a very high 


lung dose or a very high lung deposition. We 

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had six of those cases and they also 


participated in the medical monitoring program 


that we conducted from 1993 to -- to -- to the 


year 2003, which meant that we had modern lung 


count and urine data for these cases at about 


35 to 40 years after the intake. So we had a 


very good measurement of both their early lung 


deposition starting in 1965 as well as recent 


measurements with the state of the art 


techniques in the -- in -- in the 1990s and 


into the -- into the year 2000s. So we had 


both the early data and the long-term data for 


these. These were also very high lung 


deposition cases; therefore there was no -- 


there was no -- there was no issue about being 


down in the mud. They were very clean cases. 


And we had six of those from the 1969 plutonium 


fire. We had one case from the 1969 plutonium 


fire that was -- that was in building 76 and 


77. We had one case from a -- from a plutonium 


fire in a building 71 lab which was a very high 


case and we also added one case that was not 


exposed to high fired -- that was not exposed 


to a plutonium fire but was -- but was also -- 


but was exposed to a naturally oxidized 

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plutonium that was a glove failure. And then 


we have the Hanford 1 case which was a very 


well-documented case up at Hanford. 


 MR. GRIFFON: And can you -- the 872 case, the 


bounding case, was that from one of the fires 


or was --


 MR. FALK: Yes. 


 MR. GRIFFON: And how many of these cases 


involved --


 MR. FALK: That was from the 1969 plutonium 


fire. 


 MR. GRIFFON: And how many of -- of these cases 


involved chelation treatment or were these I 


guess most of them should be bounding cases 


used on chelation? 


 MR. FALK: Three of the cases for the 1969 


plutonium fire were not chelated. All of the 


other cases were. 


 MR. GRIFFON: Okay. And 872? 


 MR. FALK: 872 was a chelated case. 


 MR. GRIFFON: All right. Thank you. I just 


wanted to get the parameters there. 


 MR. FALK: We’re -- We’re fairly comfortable 


that the chelation is not affecting the overall 


model -- the calculations. Chelation for these 

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super insoluble materials is -- is largely 


ineffective. 


 MS. MUNN: Doesn’t appear to do anything. 


 MR. FALK: And you can only chelate 


systemically available material anyways. 


 MR. GRIFFON: All right. Thank you. 


UNIDENTIFIED: Excuse me. (Unintelligible). 


I’d like to ask a question. 


 MR. FALK: Sure. 


 MS. MELO: I’d like to know why 


(unintelligible). 


 MR. GRIFFON: Jim, can you paraphrase that 


question? I couldn’t hear her. 


 DR. NETON: I had trouble myself, Mark. 


 MR. GRIFFON: Okay. 


 DR. NETON: I think the question was why we 


didn’t use a USTUR case and what number was 


that? 


UNIDENTIFIED: It was 259. 


 DR. NETON: 259? 


 MS. MELO: 259, yes. 


 DR. NETON: Okay. And -- And our 


understanding is that that would have been a 


plutonium 238 case, not plutonium 239. 


MS. MELO: (Unintelligible). 

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 DR. GLOVER: May I address the case briefly? 


I’m a -- I was a radium chemist with the U.S. 


Transuranium and Uranium Registries. The case 


was a ceramicized uranium 238 material that had 


differential solubilities of function of time 


because a Pu-238 has such a high specific 


activity that it degrades the material. We are 


talking about plutonium material that doesn’t 


have that much -- the specific activity is much 


lower and it’s not going to exhibit this 


differential degradation because of that. And 


so we specifically excluded plutonium 238 from 


this TIB evaluation. That is not part of this. 


 DR. MAURO: For my edification I was aware that 


there was this distinction because of specific 


activity related to 238 versus 239. And you 


had just mentioned the reason has to do with 


the higher specific activity; but the 238 


causes it to behave physically and chemically 


differently so you refer to degradation. 


Wouldn’t that accelerate? 


DR. GLOVER: It accelerates the -- the -- the 


solubility. 


 DR. MAURO: The clearance. But what I heard 


was the opposite though. What I just heard was 

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that it was -- it was cleared more slowly. 
I 


guess I was wondering -- there was a question ­

-


MS. MELO: (Unintelligible). 


DR. GLOVER: In the first -- the very beginning 


it starts out as ceramicized material and then 


quickly begins to degrade. 


 DR. MAURO: Okay. 


DR. GLOVER: So the long-term differentials 


that we’re talking about don’t exist. 


 DR. MAURO: Got you. 


 DR. GLOVER: So they will become more 


solublized as you break the -- the chemical 


structure down, the crystal lattice, it becomes 


chemically available. 


 DR. MAURO: So if you get in the earlier time 


periods it moves more slowly but as it degrades 


it’ll clear more quickly? 


 DR. GLOVER: And that happens fairly quickly. 


 DR. MAURO: Okay. I got it. 


 MR. FALK: And by quickly what -- what are we ­

-


 DR. GLOVER: I’d have to --


 MR. FALK: Yeah. 


 DR. GLOVER: It’s been awhile since I’ve looked 

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at that case. I do have the design parameters 


for that case. 


 DR. MAURO: I have a sort of a common sense 


question. In the cases that you ran, the -- 


the slower clearance rates associated with the 


cases you picked, what -- what -- how did that 


-- what is the biological half-life for I guess 


the long-term component for S versus the 


longest-term component for the super S that you 


looked at? In other words, how much of a 


difference was the clearance rate for the -- 


the long-term compartment for the lung for the 


case that you’re using as your -- your 


representative case? 


 MR. FALK: I did not calculate that 


specifically but -- but the main -- the main 


clearance factor is in what the -- what the 


lung model calls the AI3 compartment clearing 


either to the BB1 which is the small bronchials 


or to the -- or to the lymph nodes. We used as 


the tenth minus six per day. One could -- One 


could also use the value of the tenth minus 


fifth but it basically -- but it basically 


keeps the material into the AI region which is 


actually claimant favorable relative to -- to ­
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- relative to having it go to the lymph nodes 


or -- or than to be cleared. 


 DR. MAURO: The -- In effect a tenth minus six 


per day for that compartment, for all intents 


and purposes it’s -- it’s not leaving. 


 MR. FALK: That is right. 


 DR. MAURO: So if -- if you were to run this 


very same calculation saying that it doesn’t 


leave for the purpose of doing lung dose, lung 


dose --


 MR. FALK: Yes. 


 DR. MAURO: You’d probably come up with the 


same dose. In other words, I understand why 


you would go to look into the Transuranic 


Registry to try to come up with relationships 


between lung counts I guess and clearance 


rates. But I’m looking at it from a very 


simple point of view. If we simply say to stop 


with the point of the view of the lung dose 


now, it never leaves. 


 MR. FALK: Once you get past maybe -- once you 


get past maybe 1,000 days or so, which is about 


-- which is about three years or so it -- it 


probably doesn’t clear to any noticeable 


extent. 

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 DR. MAURO: Now -- Now, the fraction that’s 


assumed to be in the slow component, is that 


also changed? In other words, I’m thinking 


(unintelligible) quite frankly my familiarity 


of the lung dynamics goes back a little ways. 


And I think in terms of the fraction of those 


to the deep lung and then its retention and in 


terms of the high fired plutonium is the 


fraction that’s assumed to go to deep lung a 


larger fraction so there -- so there really are 


two things going on? One, what’s inhaled, more 


of it is going to the deep lung and that 


portion that is going to the deep lung is 


moving a lot more slowly. Would that be a -- I 


guess I would like to get a feeling between how 


different that is from the classic, let’s say 


type S approach. 


 MR. FALK: The -- The -- The values for the 


ten cases were actually variable but it turns 


out that -- that both the HAN 1 and the -- in 


Rocky Flats 872 had a similarly fairly high 


fraction which was actually retained in a long-


term manner. But that is a -- but that -- but 


that does vary from the case to case. 


 DR. NETON: I think -- excuse me, but I think 

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John was asking is -- is -- are the deposition 


parameters different and they are. 


 DR. MAURO: Yes. They --


 DR. NETON: The initial deposition in the 


compartments of the lungs is the same. 


 DR. MAURO: Okay. 


 DR. NETON: You’re not changing aerodynamic 


properties of the materials. 


 DR. MAURO: Okay. 


 DR. NETON: And that’s pretty much based on 


where they deposit in the various regions. 


 DR. MAURO: Except if you change the particle 


sizes to reflect. 


 DR. NETON: Yeah. 

 DR. MAURO: And you looked at that, too. 

 DR. NETON: Right. Yes. 

DR. MAURO: Yes. 

DR. NETON: But -- But what does change is 

your -- it says here chemical solubility and/or 


your mechanical clearance properties. Now, it 


turns out in developing these models you 


couldn’t shut down the clearance enough. If 


you shut down the clearance to almost nothing 


your mechanical -- your chemical clearance, 


your mechanical clearance was still clearing it 

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much too quickly based on -- based on the super 


S -- the type S model. So in essence they had 


to close down some of the clearance properties 


as well, mechanical clearance properties. 


There are a couple things going on. 


 DR. MAURO: Right. 


 DR. NETON: And no one really quite understands 


this but for large doses people speculate that 


there is actually tissue damage, fibrotic 


lesions that --


 MS. MUNN: Must be. 


 DR. NETON: -- but no one really knows because 


you can only see and measure these effects in 


large inhalation cases. If -- If they’re 


small you wouldn’t see them necessarily and 


then, you know, you wouldn’t know. 


 MR. GRIFFON: Okay. Any further discussion on 


the issues? I’m a little bit concerned -- this 


-- this ceramic materials -- first of all I’ve 


heard the statement that there was a lot of 


plutonium 238 at Rocky Flats. Is that --


 MR. FALK: No. 


 DR. NETON: I didn’t think that was an issue. 


 MR. FALK: There was a trace amount in weapons 


grade on the order of maybe 200 parts per 

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million. It wasn’t a very significant 


component. 


 DR. NETON: So it seems to me a design case 


would be based on plutonium 239 because of this 


differential solubility issue and the 


ceramicized oxide. I'm not sure where this 


case is from, what site. Dunstana, do you know 


which facility the USTUR 259 came from? 


MS. MELO: What? 


 DR. NETON: Do you know which DOE facility the 


case that you spoke of -- 


 MS. MELO: Los Alamos. 


 DR. NETON: Los Alamos? 


 MS. MELO: Los Alamos. 


 DR. NETON: Right. 


 DR. MAKHIJANI: Roger, this is Arjun. Weren’t 


there plutonium 238 RTG’s made at Rocky Flats? 


 MR. FALK: What type? 


 DR. MAKHIJANI: RTG’s. 


UNIDENTIFIED: RTG’s. 


 MS. MUNN: RTG’s. 


 DR. MAKHIJANI: Did Rocky Flats manufacture 


RTG’s? 


UNIDENTIFIED: Thermal generators. 


 DR. MAKHIJANI: Thermo-electric radio-isotope 

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(unintelligible). 


 MR. FALK: I am not aware of that. 

 MS. MUNN: I thought it was all Los Alamos and 

Hanford. 

 DR. MAKHIJANI: So I guess --


UNIDENTIFIED: Hello? 


 MR. GRIFFON: (Unintelligible) manufactured the 


heat source for that. 


 DR. NETON: Right. 


 MS. MUNN: Uh-huh. Yeah. 


DR. NETON: So it seems to me that the issue 


with USTUR 259 has to deal with two things. 


One is it was plutonium 238 which does not 


appear to be in -- present in significant 


quantities at Rocky Flats. And secondly I 


think the ceramicized matrix issue is something 


special possibly for Los Alamos. And I think 


we’re fairly comfortable using Rocky Flats 


cases to do Rocky Flats calculations as well. 


So okay. 


 DR. MAKHIJANI: Before we leave that, I have -- 


I have a document here, a Rocky Flats 


(unintelligible) from the 1990s that talk about 


(unintelligible). And 107 items, 12 of which 


are americium 241, 38, plutonium 239, 57, 

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plutonium 238. They also have a 


(unintelligible) 90. Now, they may have come 


from outside, obviously, sources. It doesn’t 


say -- this is a remediation document, 


management document, so I could not tell 


whether they were made there or whether they 


were imported. 


 DR. NETON: If they were imported, it by 


definition (unintelligible) sources. 


 DR. MAKHIJANI: Yeah. No, so then -- then you 


wouldn’t have an issue. 


 DR. NETON: Right. 


 DR. MAKHIJANI: But if they were made there 


then obviously these various -- I’d be happy to 


email you because you know this. 


 DR. NETON: Okay. Okay, if there’s no other 


questions on this. 


 MR. GRIFFON: Jim? 


 DR. NETON: Yeah. 


 MR. GRIFFON: Jim, just one other question on 


TIB 49. I’m looking at the very back of page 


37. 


 DR. NETON: Yes. 


 MR. GRIFFON: And again I’ve just quickly 


looked at this, the HAN-1 and the RF872 cases ­
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-


 DR. NETON: Uh-huh. 


 MR. GRIFFON: Those -- Those parameters there 


 DR. NETON: Yes. 


 MR. GRIFFON: They were derived from the lung 


data. How -- How -- How did you -- How did 


you come up with those parameters? 


 DR. NETON: Well, Roger could probably speak 


better but they were fit using the IMBA 


software, you know, intake to bioassay and 


you’ve got -- you’ve got lung monitoring data 


and urine -- urinalysis data for these cases. 


And -- And the moral -- the analysis to give 


it the best fit to the available data generated 


those parameters. 


 MR. GRIFFON: Okay. Because we have some 


problems, well, some differences, you know. 


DR. NETON: You can see -- You can see them 


plotted over the top of each other on page 35 


and --


 MR. GRIFFON: Right. 


 DR. NETON: -- they virtually overlap except 


for, you know, the earlier time periods. As I 


said, both models -- both calculations were 

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used and the one that gave the higher derived 


lung adjustment factor would be applied. 


 MR. GRIFFON: Right. 


 DR. NETON: I do think that this represents in 


our mind a bounding -- a bounding scenario. 


Now that -- that -- that will account for the 


adjustment for the lung doses but you have 


another issue when you want to start 


calculating intake because you’re going to rely 


on something such as urine samples. And by 


definition since the material leaves the lung 


more slowly, then what’s known as the intake 


retention fraction is going to be different for 


the more insoluble material. You’re going to 


have less coming out in the -- in the urine per 


unit inhalation for the super S material than 


you would for the S type material. To account 


for that we --


 MR. GRIFFON: Can I just step away for one 


second and understand this, Jim? I'm sorry. 


 DR. NETON: Yeah. 


 MR. GRIFFON: It looks to me like these are 


pretty much -- these sets are -- are they just 


based on simply mathematical sets or are they 


empirical because it looks like you’re 

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adjusting any parameter you need to to get the 


best fill-in data. I’m wondering if -- if 


there’s a point where you can say, you know, 


well, we -- we don’t have any reason from a 


biological standpoint to modify these 


parameters differently in the same sets of 


cases. Do you know what I’m saying? 


 DR. NETON: Not really. I mean you have what 


you have to modify. You have chemical 


clearance and you’ve got mechanical clearance. 


And when you start modifying those parameters 


you need to fit -- fit -- you know, you have to 


fit what’s coming out of the lung somehow. 


 MR. GRIFFON: Right. Right. 


 DR. NETON: And as I suggested, almost shutting 


down the chemical clearance totally still allow 


for too much lung clearance so clearly there 


was a mechanical component involved. But Roger 


could speak for what selection criteria we used 


for fit as a subject expert. 


 MR. FALK: It was mainly the -- it was mainly 


the empirical type of the approach, and using 


the principle that I want to look at the ones 


that make the most changes and I want to make 


as few of changes as I can. And so we’ve 

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looked at the particle clearance. I first fit 


the lung data to -- to -- to get the 


approximately fit and then I used the 


absorption parameters to then -- then fit the ­

- then fit the urine data in order to get the 


same intake assessed by the IMBA code for both 


sets of data independently. So that was my 


basic approach. 


 MR. GRIFFON: Okay. The only thing I’m 


wondering is, you know, if you then went back 


and said, okay, for all these parameters if I 


had (unintelligible) and I know that’s not what 


we’re doing here but if you had to come up with 


a constant for a, you know, a super S model 


then, you know, these -- these numbers -- I 


only see two of them but I’m guessing that they 


-- that these parameters don’t fall all over 


the place. 


 DR. NETON: I'm not sure where you’re -- you’re 


getting at there, Mark, but I -- I think -- I 


think what you’re saying is that there’s a lot 


of variability among these cases and there are 


and that’s why we deliberately chose the ones 


that had the longest clearance times. We’re 


not really developing a new super S model. 

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We’re doing a bounding analysis is what I’d 


like to call it. And -- And we’re very 


confident that it -- the model -- the lung 


calculation adjustments are -- fairly represent 


the upper limit of the clearance times that one 


would experience with Rocky Flats workers 


inhaling insoluble material. 


 MR. GRIFFON: Okay. That’s as far as I’m going 


to take that one. Thanks. 


 DR. NETON: Yeah. I think you might be -- 


might be a little more -- 


 MR. GRIFFON: That’s really what I’m looking at 


is the variability question, yeah. 


 DR. NETON: And that’s why we -- we -- we 


prefer to call these bounding analyses just 


because of that, that, you know, clearly we 


have ten cases and there’s -- there’s 


variability even among super S. And the 


original thought could be, well, let’s take the 


-- the central estimate and put some 


distributions about that and assign dose 


clearance parameters to the work force. But we 


weren’t comfortable with that -- 


 MR. GRIFFON: Right. 


 DR. NETON: -- because there -- there is still 

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a lot of unknowns so we said let’s take the 


ones that exhibit the longest clearance times, 


in fact, the two that did, and use the most 


conservative of those two in every step of the 


way. So --


 MR. GRIFFON: Okay. 


 DR. NETON: Getting back to the next point 


though is that if you want to now estimate 


intake, how much plutonium did the person 


inhale at times zero, this analysis of course 


doesn’t tell you that if you -- if you start 


from a urine sample. If you start from a lung 


measurement it’s okay because you -- you -- it 


is what it is. Or if you start from an air 


sample and you inhale, what’s deposited is 


deposited. If I want to now impute or infer a 


lung measurement -- a lung intake based on a 


urine sample we need to look again at the 


differences in what’s coming out in the urine 


versus the super S versus the S. And again 


since we are not saying that these -- this is 


the definitive model we looked at the 


difference in intake retention fractions at all 


time periods post-intake that were projected by 


these calculations, and determined that at -- 

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at any point along the way for chronic intake 


scenarios there is no more than a factor of 


four difference projected in intake. That is I 


think a urine sample at any time post-intake 


using the super S calculation or the S, I will 


infer no more than a factor of four difference 


in intake. In some cases it’s much closer than 


that, and that’s what’s recorded in figure 1 


where we compare the different clearances. In 


fact we did the analysis for both HAN-1 and 


Rocky Flats 872. It turns out that HAN-1 


projects the largest difference in intake and ­

- and you can’t read it necessarily from the 


graph but you’ll have to trust me that’s about 


a factor -- it is a factor of four I think 


rounded up from 2.9. So given that then, we 


are proposing in this I’ll call it a white 


paper right now, in our approach to dose 


reconstructions with super S, that we would 


take any intake that was derived from a urine 


sample that assumed type S and multiply it by a 


factor of four at any point along the way. So 


essentially we’re adjusting upwards all intakes 


by a factor of four to account for this 


difference in -- in -- the lower amount of 

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uranium -- of plutonium appearing in the urine 


over time. We did a similar analysis on acute 


intake scenario and it turns out it can be 


larger than a factor of four after about a year 


but under any credible scenario that we feel we 


would be evaluating we would be doing that 


acute intake analysis much closer in than -- 


than -- than a year. And again the factor of 


four seems to apply pretty nicely for that 


analysis. And that’s what’s plotted in figure 


2. 


 DR. MAKHIJANI: Can I ask a question about that 


time frame? 


 DR. NETON: Yeah. 


 DR. MAKHIJANI: In the petition it cites an 


example if I remember correctly where an acute 


intake was detected much after the intake only 


on routine analysis. And so I wonder whether 


you can make that assumption? 


 DR. NETON: How much -- How much after I 


guess? 


 DR. MAKHIJANI: I think it was like a -- it was 


actually on the order of a year. Is there a 


petitioner? I can look it up. I’ve got it in 


my notes somewhere but -- 

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 DR. NETON: Well, I think that if we know -- if 


we know the specifics of the case we would 


apply what the specifics were. But if you --


if you do the analysis, and Dave Allen can back 


me up on this, if one assumes -- if one has a 


positive urine sample, and let’s say that that 


positive urine sample is taken well -- a year 


or more after -- and it was an acute intake, I 


mean we would model it as a chronic intake 


exposure scenario. That is giving a person 


chronic intake all the way up to there. We 


would -- we would bound his -- his dose using 


that analysis. That’s typically our approach. 

We --

 DR. MAKHIJANI: Yes. 

 DR. NETON: We’ve been down this path at the 


other meetings where we’ve shown that chronic 


intake scenarios are more claimant favorable by 


and large than the acute intake. 


DR. MAKHIJANI Yeah. Generally we have -- 


we’ve done this. I think we did this in -- 


DR. NETON: I forget where it was but we did -- 


we’ve done that. Am I pretty much on target 


with that, Dave? 


 MR. ALLEN: Yes, we are. 

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 DR. NETON: So --


MR. ALLEN: Assuming that -- that chronic 


exposure doesn’t stop the day of the sample. 


 MR. GRIFFON: Can’t hear a word you’re saying. 


MR. ALLEN: I’m sorry. I’m back from the table 


a little bit. It’s assuming that the -- it’s 


assuming that the chronic intake doesn’t stop 


the day of the sample. If we’re collecting a 


sample that turns out to be high and it’s a 


year after an acute intake the odds are we’re 


not going to realize there was an acute intake. 


We’re going to (unintelligible) his on past 


that date and this ends up being favorable to 


(unintelligible) a short time after that date. 


DR. NETON: Okay. So let us talk a little bit 


about the different scenarios that one can 


envision. For the lung if we estimated the 


lung intake we would just apply that factor 


four and -- and use that. If it were a GI 


tract dose we were trying to estimate we would 


again increase by a factor of four. You would 


have the -- a lot -- it turns out a lot of the 


GI tract doses (unintelligible) a clearance 


from what is called ET 1 and ET 2, the extra 


thoracic regions of the lung that this factor 

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of four would boost up and provide a fairly 


large GI tract dose. We would clear that 


factor of four dose to the GI tract with type S 


parameters. In other words, we wouldn’t -- we 


wouldn’t allow for this lower clearance. We 


would just clear it out. And it wouldn’t make 


a huge difference I don’t think because most of 


the dose comes -- the majority of the dose 


comes from the early clearance of not the lung 


but the thoracic regions. When we’re talking 


about systemic organs though, those that have 


to become irradiated after the plutoniums reach 


the blood streams, we have a slightly different 


approach here. It is our opinion -- it was at 


the last Board meeting and it’s still our 


opinion that the -- the amount of material 


that’s in the blood stream is directly 


proportional to the dose that’s delivered to 


the organ. So we would clear the material from 


the -- from the lung we would use a type S 


model. While -- Up to the date of the last 


bioassay sample we were applying a type S model 


to clear all the plutonium out of the lung and 


then after the last bioassay sample there’s a 


problem because you have this potential 

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reservoir of additional plutonium that you 


don’t know about. And so then we proposed 


after the person left the workforce and was no 


longer monitored to increase those values by a 


factor of four to account for this residual 


reservoir. I think this is where we had a 


slight disconnect at the last meeting. You do 


get a higher dose because you certainly have a 


higher intake but the dose during the 


monitoring period itself is the -- I mean you 


only have so much plutonium you can have in the 


urine given a certain bioassay profile. So 


that does a slight twist there with the 


systemic organs so I’ve covered lung, GI tract, 


ET 1, ET 2 and systemic organs. I think that 


covers the waterfront on -- on those -- on 


those types of calculations. We went an 


additional step further and I mentioned at the 


last meeting, we had the Transuranic Registry 


cases. It turns out these comparisons were 


more difficult than we would like and -- and it 


-- for many of the same reasons that Roger 


mentioned we’ve tried to obtain clean cases, 


cases that were not confused by repeated 


exposures or they had a high enough -- a 

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sufficient intake to be detectible above the 


noise because if you -- if all of your bioassay 


samples in the Transuranic Registry case are 


below detectible it doesn’t do you any good. 


You need to have some positives in there to be 


able to -- to do some comparisons. Nonetheless 


we went ahead and did a comparison of what was 


available and that was provided at the very end 


of the document, sort of as what I like to call 


an independent plausibility evaluation. In 


other words, you know, we’ve -- we’ve made a 


couple conservative assumptions at several 


steps along the way. Does this put us in the 


realm of -- of -- of -- of ridiculous? Are we 


way overestimating? It turns out we do 


overestimate but the factors where inhalations 


were involved were not really out of the -- the 


realm of plausibilities. And in fact this 


analysis that we’ve done is shown for the -- 


how many there were --


UNIDENTIFIED: It’s -- It’s --


 DR. NETON: Table 2. 


UNIDENTIFIED: Table 2, last page, 8? 


 DR. NETON: Yeah. There were seven cases we 


were able to compare. The techniques that -- 

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adjustment factors, techniques that I just 


described would be overestimates if we applied 


them to the Transuranic Registry cases in the 


manner that we would normally reconstruct a -- 


a intake. That is, assume a chronic intake 


exposure scenario for the duration of their 


employment. That’s the nickel tour of where 


we’re at. Certainly I’m sure you folks have a 


lot of questions they want to ask. Let’s open 


up the floor. 


 DR. MAURO: I’ll start off with probably a dumb 


question. When I look at figure 1 on your 


report, let’s just -- let’s say I want to use 


figure 1. 


 DR. NETON: Uh-huh. 


 DR. MAURO: I have an individual and what we’re 


saying is he’s -- he’s chronically exposed and 


I go in -- I go in at one year, you know, 365 


days which collapses you right up close, and 


then pull a urine sample. Okay. And I don’t ­

- I don’t have any idea whether he was exposed 


to high fired type S, N, or F. Just don’t 


know. But I suspect he’s -- he’s chronically 


exposed to plutonium. Now, according to this 


set of graphs what -- what this is if I assume 

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that this chronic exposure is type S, I’m going 


to come up with my highest intake per unit 


excretion. In other words, whatever you 


observe in his urine, whether you assume and 


say one-half of the MDL or at some detected 


level, the intake that you’re going to -- the 


chronic intake rate is going to always be 


bounded by assuming that he’s being exposed to 


type S. That is --


 DR. NETON: Type S times four. 

 DR. MAURO: So this table includes the four. 

DR. NETON: That’s what I don't know if you can 

probably see the graphic because it’s -- we do 


that in black and white copy but -- 


 DR. MAURO: No, no, I have a colored copy. 


DR. NETON: It’s on the right. It’s the third 


one down which is the -- 


 DR. MAURO: Oh, I -- Yeah. I'm sorry. 


 DR. NETON: -- gold line. 


 DR. MAURO: I -- I -- you’re absolutely right. 


 DR. NETON: So what we’re trying to show here 


is type S which is the green line, would 


project that. 


DR. MAURO: I was looking -- I was looking at 


the type S, not the --

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 DR. NETON: What was very nice about the -- 


 DR. MAURO: As I said, it was probably going to 


be a stupid question, and it was. Now at least 


I understand. 


 DR. NETON: That was our intent to, you know, 


we’re not extremely confident in all aspects of 


this model so we’ll just take the factor of 


four and apply it for all times post-intake 


which we think works out very well for us. 


 MS. MUNN: You’re certainly generous. It’s 


bounding from the graph. 


 DR. NETON: Any additional questions? 


 DR. MAKHIJANI: Let me -- let me -- I -- I 


think the -- the comparisons of the S -- super 


-- and super S (unintelligible) studied it a 


great deal sort of correspond to some of the 


analyses that -- that back of the envelope or 


preliminary work that we did but the question 


that I have in regard -- there’s a -- there’s a 


question in the petition about mixed intakes. 


So if you have type F, type M, type S, super S, 


how do you actually -- that would be a 


practical situation for a worker and there’s a 


explicit item in the petition claiming that it 


would be hard to do that back or difficult to 

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do it or possibly to do it. And -- And just 


to make the question a little bit more 


simplified in my own mind, I pos-- I postulate 


suppose you -- you’re into routine bioassay. 


We have an acute intake and you do a bioassay 


six months or one year after the intake and it 


is type F material. How would the systemic 


organ doses compare because if you -- 


especially if you have below minimum detectible 


-- say you have just below minimum detectible ­

- you have just below MDA after six months or a 


year your intake from type S would be quite 


high, higher than possibly the real -- maybe 


the type F. I do not know because it was very 


short (unintelligible). 


 DR. NETON: Yeah. Yeah. Well, Dave, do you 


want to --


 MR. ALLEN: Well, the whole intent -- I mean 


what we’ve been doing all along is taking all 


the credible probability types and taking, you 


know -- taking the most claimant favorable 


ones. And what we’re proposing with the super 


S’s is just one more -- one additional credible 


solubility thing. So if type F is credible, 


which it’s -- it’s not a default with the 

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plutonium -- we’ve done type M -- 


 MS. MELO: (Unintelligible). 


 DR. WADE: Dave -- Maybe you can come up here, 


Dave, and join us at the table. 


 MR. ALLEN: Sorry. Yeah. I’ll just begin 


again. What we’ve done in the past is taken 


all the credible solubility types and assumed 


the worst case one. In the case of plutonium 


what we’re proposing is that this super S would 


be an additional solubility code so we would 


run it as a super S, a type S and a type M and 


pick the most favorable if they’re all 


credible. 


 DR. MAKHIJANI: So the like plutonium 


trifluoride and tetrafluoride and so on? I 


mean I -- I don't know all the chemical forms 


that are there at Rocky Flats. I haven’t made 


a list but -- but you made a list and excluded 


type F? 


MR. ALLEN: Well, ICRP excluded type F for 


plutonium. 


 DR. MAKHIJANI: Altogether? 


 MR. ALLEN: Yes. 


 MS. MUNN: Arjun, question about the case that 


you mentioned in the SEC. I don't remember. 

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50 

That’s been awhile since I read that. 


 DR. MAKHIJANI: There wasn’t one specific case 


so far as I recall but there was sort of a 


bullet point type of item in there to the best 


of my memory. I might be corrected by a 


petitioner because there were a lot of 


affidavits and I have not read them all 


carefully. That the problem of mixed 


solubilities would present issues in dose 


reconstruction and so I tried to kind of juggle 


that in my mind and -- and -- 


(Music plays) 


DR. WADE: Someone put us on hold maybe. 


UNIDENTIFIED: Right. 


DR. WADE: Can you hear us? 


UNIDENTIFIED: (Unintelligible). 


(Music plays) 


DR. WADE: Can --


MR. GRIFFON: (Unintelligible). 


DR. WADE: No, somebody’s put us on hold. Can 


you hear me speaking? 


 MR. GRIFFON: (Unintelligible). 


UNIDENTIFIED: Who came back on? 


 DR. WADE: What we’re going to do is try and 


lower the volume of that noise and assume you 

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can hear us. 


(Phone rings) 


DR. WADE: Wait a minute. Maybe something will 


happen now. 


 MS. MUNN: He’s not home. 


 DR. WADE: Just wait for a minute. 


(Phone answering machine message: Hi, this is 


Kay Barker. I’m either away from my desk or on 


the phone. If you’d like to leave a message 


please (unintelligible) operator. Have a good 


day.) 


UNIDENTIFIED: I don't know. 


 DR. WADE: Kay Barker? Any way -- anybody know 


Kay Barker or is Kay Barker hearing my voice? 


 MS. BARRIE: I do know Kay Barker. I’ll email 


her. 


 DR. WADE: Yeah, would you, please? She’s 


destroying the whole -- the whole working here. 


 MS. MUNN: Actually it was Kay’s answering 


machine. Someone was trying to reach her. 


 DR. NETON: Yeah, it was someone trying to 


reach her. 


 MS. MUNN: Yeah. So we don’t know who that is. 


They put us on hold to do that. 


UNIDENTIFIED: Well, the music stopped. Can 

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everyone hear? 


 DR. WADE: Can you hear me now? 


 MR. GRIFFON: Yeah, I can. 


 DR. WADE: Okay. We’ll start back again. 


Please, also before that happened someone was 


obviously fiddling with something on their desk 


or something mechanical and we could hear each 


noise. So if you’re going to be on the 


speakerphone then mute us, please, and respect 


everyone else’s ability to participate. 


(Phone recording plays) 


DR. WADE: Okay. We’re going to try and 


continue our business. Again, we ask everybody 


out there to sort of police your actions 


respectfully. Otherwise we won’t be able to 


have these kinds of calls and I think a great 


deal of important work will be left undone. So 


we’ll start again. 


 MS. MUNN: I hate to continue because Arjun’s 


not in the room but perhaps someone else can 


answer the question. If we’re not -- are we -- 


are we just speaking in generalities here? No 


-- No one is suggesting that there is a 


circumstance where there would be an acute 


intake of all these different types of 

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solubilities. They’re talking about the 


possibility of individuals changing jobs or 


handling different types of material over the 


course of a period of years; is that the issue? 


 DR. NETON: I think so but --


 MR. GRIFFON: (Unintelligible). 


 DR. NETON: Either way though I think that as 


Dave Allen pointed out, we -- it’s been our 


standard practice to evaluate the plausible 


scenarios and pick the one that would provide ­

- if we couldn’t tell, differentiate among the 


exposure types, pick the one that would result 


in the highest dose to the organ. So, you 


know, if there was a mixture of 50/50 and we 


assumed it was all one type that would be the 


type that would give us the highest dose to the 


organ. 


 MR. GRIFFON: So -- So Jim, I guess the 


question relevant to super S would be is there 


-- and I don't know if there’s enough of a 


handle as to where this may have been an issue 


-- where you can determine from the urinalysis 


whether it may be extension (unintelligible) 


urinalysis that you have, you know, a lot of 


your numbers, say for example super S exposures 

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that you’re not aware of; do you know what I 


mean? 


 DR. NETON: Right. And the way we’ve done our 


adjustment factors we would apply a factor of 


four intake above the S and evaluate the dose 


to the organs. We -- We --


 MR. GRIFFON: For any case that you were -- 


 DR. NETON: That’s right. 


 MR. GRIFFON: Okay. 


 DR. NETON: We would -- We would --


 MR. GRIFFON: And you have enough -- you have 


enough handle that you could narrow it down 


(unintelligible) super S was an issue at Rocky 


or -- or would it be done across the board or 


I’m not --


 DR. NETON: Well, it would be pretty much 


across the board on handled plutonium. I mean 


there were early assertions that this was just 


related to the fire but there are other 


indications that other types of plutonium may 


be equally insoluble so this would be pretty 


much handled across the board if we didn’t know 


any better. I mean if we knew the exact type 


we would assign them but if we don’t know, 


super S would become one of our -- one of our ­
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-


 MR. ALLEN: Plausible classes. 


 DR. NETON: -- plausible classes, right. So --


And what you’re talking about here as I -- as I 


discussed previously, you’re increasing the one 


dose by quite a bit but the lung -- most of the 


lung cancers are already compensated so that 


really is -- I mean there are some that are on 


the borderline that might fall in under this 


new approach which is why we went that way, but 


then even when you increased the intakes by a 


factor of four the systemic organ doses that 


don’t concentrate plutonium still don’t get any 


internal dose to an appreciable degree because 


they just don’t concentrate the material. 


 MS. MUNN: Yeah. 


 DR. NETON: So -- And we will -- we will 


document this with some example dose 


reconstructions I think. This would be a 


perfect case where we would show that you -- 


even with these factor of four adjustments you 


end up with plausible doses to the individual 


organs and, you know, which ones would be 


likely compensable under certain scenarios, 


that sort of thing. 

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 MS. MUNN: And that continues to be a concern, 


how far outside of plausibility -- 


 DR. NETON: Right. 


 MS. MUNN: -- do you get when you start adding 


factors of four. 


 DR. NETON: Right. But with super S I, you 


know, I feel we’re -- we’re -- we’re not 


implausible. I think that clearly there are 


cases where this stuff just doesn’t move out -- 


out of the lung. 


 MS. MUNN: No, the graph shows that. 


DR. NETON: The trick is when you get these 


factor of four differences in intakes and then, 


you know, you have to account for that in the 


systemic organs. And that’s what we’re going 


to do. I mean that’s what we’ll account for 


after the last bioassay sample. 


 MR. GRIFFON: Can I just go back to one more 


question on that, the clean cases question. 


How many -- how many people were involved in 


these fires or what was the (unintelligible) 


data that you looked at or -- or Roger looked 


at to identify the clean cases that you were 


going to use in this model? 


 DR. NETON: Roger? 

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 MR. FALK: That’s hard to qualify. Basically 


for the 1969 fire there are about 200 people 


who were in the building who were -- who were 


carded after that. Now -- Now -- Now, there 


were only 25 cases that were noted to be over 


the one lung burden range at that time. And so 


-- but there is a whole spectrum of the cases. 


And one wants to look at the highest cases that 


have the best good long-term data that we can. 


 MR. GRIFFON: Okay. 


 DR. GLOVER: And then these were compared to 


over 120 Rocky Flats USDR cases as well to kind 


of verify the -- the plausibility of the -- of 


the scenario. We had people who were exposed 


in the 1969 fire, two later fires, to a variety 


of scenarios where this potentially could be 


applicable. 


 MR. GRIFFON: How many USDR cases? 


 DR. GLOVER: A hundred and twenty autopsy cases 


have been done for Rocky Flats. 


 MS. MUNN: That’s good. That’s a good sample. 


 MS. MELO: And I (unintelligible) parameters 


(unintelligible). 


 DR. WADE: We’re having great difficulty 


hearing you. 

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 DR. GLOVER: I think I caught her. We had 


already answered that earlier. We did try 


doing that, just changing the absorption 


parameters and the mechanical clearance was too 


fast. It -- It lowered the lung content 


faster than what the -- 


 MR. GRIFFON: (Unintelligible). 


 DR. GLOVER: -- were shown. 


 MS. MELO: (Unintelligible). 


 DR. GLOVER: I didn’t catch that. 


 DR. WADE: Well, you have to speak louder and 


if you have a handset, please use the handset. 


 MS. MELO: Yes. (Unintelligible) transport 


(unintelligible). 


 DR. GLOVER: Mechanical transport -- 


 MR. GRIFFON: (Unintelligible) data you have to 


(unintelligible) as well, right? 


 DR. NETON: Right. 


 DR. GLOVER: Right. 


 DR. NETON: It was necessary to change the 


mechanical transport to account for the overall 


slower clearance. 


 DR. MAURO: Is that what that ten to the amount 


of six per day is? In other words, that number 


is the number you have to sort of get into your 

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model in order to allow it to do what you 


wanted it to do based on the empirical data to 


get -- in other words it was ten to the amount 


of six per day. 


 DR. NETON: I think that’s the chemical 


solubility. 


 MR. FALK: No, that is the particle transport 


from the AI3 region. 


 DR. MAURO: Okay. 


 MR. FALK: And we had to basically stop I 


thought. 


 DR. MAURO: You had to shut that -- 


 MR. FALK: Yes. 


 DR. MAURO: -- dramatically. In the end what 


is the end, the clearance rate? 


 MR. FALK: It doesn’t seem like there is much. 


 DR. MAURO: In other words, for all intents and 


purposes it’s sealed. In other words, frozen. 


And -- And when you do that -- 


DR. NETON: I also have zeros down because we 


-- we couldn’t have anything in the 


(unintelligible). 


 DR. MAURO: No, no. Everybody’s --

DR. NETON: You can’t have it both ways. 

DR. MAURO: Well, no, no. In other words, 
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mech-- here -- here we have a daily intake for 


unit exclusion. Okay. And embedded in that is 


some clearance model. Now, if you were to 


assume that your -- you take a urine sample. 


You see -- You don’t see anything. You don’t 


see anything because nothing is there. Okay. 


But you say, well, wait a minute. We don’t see 


anything. We’re going to assume it’s one half 


the MDL or the MDL, whatever. You’re going to 


pick a number. Then you’re going to say if 


that -- now, we realize that these two things 


can’t happen at the same time but assuming it’s 


at one half the MDL but -- let me try -- this 


doesn’t -- see if this makes sense or not -- 


then you’ll come up with an intake that’s based 


on your graph here that tells you how much is 


taken in. Okay. Now I have my intake rate and 


I have my becquerels per day coming in now. 


Then I go ahead and I run a calculation. If I 


have these becquerels per day coming in and I 


assume it all -- none of it’s leaving -- now we 


assume that none of it’s leaving. Of course 


the two are -- does -- does that change your 


dosing? In other words, for all intents and 


purposes is that what you’re doing? Did I pose 

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my question the way that -- in other words, you 


come up with an intake based on your -- your 


model on figure one. 


 DR. NETON: Right. 


 DR. MAURO: And now I have my intake. Now I’m 


going to -- now, what you’re saying is I’m 


going to calculate my dose right now to the 


lung by assuming that the clearance -- that the 


-- it’s four time -- I guess the clearance rate 


is -- what -- your intake is as if it was four 


times S. 


 DR. NETON: Right. 


 DR. MAURO: Now you’ve got your -- you have 


your intake. I have my -- I have my 


becquerels per day. Now I’m going to calculate 


the dose to the lung. Now, embedding that dose 


to the -- the lung is some assumptions is how 


quickly it’s being cleared. Now, if I assume 


that it’s not being -- it isn’t, whatever I 


assume is my intake rate, is this staying 


resident permanently in the lung? 


 DR. NETON: Well, that’s not what we’re doing. 


 DR. MAURO: No, no, I want to see if that -- 


because that sort of like puts a point at the 


end of the sentence. It can’t be worse than 

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that. 


 DR. NETON: Well, that’s true. But what you 


have is the adjustment factors that if it -- if 


it were to clear as type S it has a certain 


rate. And if it did clear as super S as we 


calculated --


 DR. MAURO: Right. 


 DR. NETON: -- there is -- the gist of TIB 49 


are adjustment factors of the dose. How much 


more dose am I going to get per year because 


they’re cleared -- it’s clearing slowly. So we 


just adjusted the doses upward for the -- to 


the lung. 


 DR. MAURO: The reason I’m posing a question 


and I’m struggling with it is that you have 


this empirical data that represents some number 


of workers, some of which it appears that the 


material is clearing very slowly; perhaps 


others not clearing that slow but -- and a lot 


of the questions that are emerging have to with 


how -- how confident are we that out of this 


collection of cases that you looked at -- 


(Loud noise) 


 DR. WADE: There’s a great deal of noise coming 


from someone. 

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63

 MS. MUNN: Don’t go away. Except you who are 


making the noise. Go away. 


 DR. WADE: I don't know if that’s just a 


(inaudible). There’s a great deal of noise 


coming from someone. 


(Noise stops) 


DR. WADE: Okay. Whoever just did something 


fixed it. Don’t do that anymore. 


 DR. MAURO: Where I was headed, and what I’m 


struggling with here is that ultimately the 


rock you’re standing on are empirical data from 


individuals who worked at Rocky who were 


exposed to high fired plutonium. And it 


represents some finite number of cases that -- 


that we’re assuming captures the range of 


conditions that all workers may have 


experienced. Now, I always ask myself, well, 


what happens -- is it possible -- what happens 


if we’re wrong. I’ll go back to what I did 


before. What happens if it turns out that 


there are exposure situations where the high 


fired plutonium was even more recalcitrant? 


That is, it just isn’t leaving to the extent 


that it doesn’t ever leave. It just -- In 


other words, it’s not -- would things change 

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any? For all intents and purposes that’s what 


we have. First of all, does my question make 


sense? Do you understand where I’m going with 


my question or -- or am I missing the point in 


a way? See, I’m trying to say that maybe -- 


maybe you’ve picked a case for all intents and 


purposes that can’t be any worse than that. 


 DR. NETON: I think that’s what we’re 


suggesting is that we’ve looked at ten 


individual cases with fairly high exposures 


where we had good data and we picked the worst 


two cases of that which were very similar. 


Now, you know, do we have all possible exposure 


scenarios covered? I don't know. 


 DR. MAURO: Well, what I’m saying is that -- 


and if it turns out that for all intents and 


purposes from the point of the lung dose it 


doesn’t really matter because you’re assuming 


for all intents and purposes it’s not leaving 


the lung so it can’t be any worse than that. 


In other words, I’m trying to -- 


DR. NETON: That’s not necessarily true. 

 DR. MAURO: -- close here. That’s not -- Okay. 

 DR. NETON: There is -- it’s not going very 

fast but it is clearing, I mean to some degree. 

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I mean the doses, it’s -- it’s close to not 


clearing but again if it didn’t clear from the 


-- the lung at all we wouldn’t be able to 


measure it in the urine. 


DR. MAURO: Oh, I understand. 


DR. NETON: And in fact if it didn’t clear from 


the lung at all there’d be no dose to the 


systemic organs. 


 DR. MAURO: What I’m saying is that for most of 


our cases we’re going to have cases where we 


don’t see anything in urine. We -- We know 


that. 


 DR. NETON: But we’re going to assume, like we 


do with normal missed dose calculations -- 


 DR. MAURO: Right. 


 DR. NETON: -- that it’s LOD over two. 


 DR. MAURO: Right. That's right. 


 DR. NETON: And then we’ll multiply those 


intakes, if they were S times a factor of four 


 DR. MAURO: Right. 


 DR. NETON: And say, you know, we’re not sure 


exactly what it is but based on the bounding 


analysis we’ve done with the ten cases -- 


 DR. ULSH: And you also have to keep in -- 

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sorry, go ahead. 


 DR. NETON: And I was just (unintelligible) if 


you look at the ten design cases it’s a log 


scale. There -- There’s a pretty substantial 


gap between the third highest case and -- and 


the two that we’ve chosen. I mean that’s not a 


trivial difference. So, yeah, I think it’s a 


fairly representative sample -- representative 


sample of these -- of these exposures. 


 DR. ULSH: You also have to keep in mind we’re 


talking about urine data here but we also have 


lung count data and that’s the piece that we 


haven’t really talked about explicitly here. 


think if you could get a handle on could there 


be cases where there’s even slower clearance 


than what we’ve estimated and we don’t see that 


from the lung count data; is that correct, Jim? 


 DR. NETON: Well, I mean that’s what it shows 


here, I mean with the design cases. I think 


there’s also this effect that we’ve talked 


about where there -- there are some people 


postulate that the higher exposures actually 


clear more slowly because of the damage that’s 


done to the lungs just from the -- 


 DR. MAURO: Yeah. 


I 
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 DR. NETON: -- alpha fibrotic lesions that are 


created because of the high activity. So in 


some sense if that were true then this would 


certainly be -- would even emphasize more the 


fact that they are more likely bounding 


analyses. I can’t prove that but that would 


support that contention. 


 DR. GLOVER: One piece of evidence, to -- to 


say that it never clears, even thorium dioxide 


has self-inflicted damage sites that breaks 


(unintelligible). So even these -- there will 


be some self-induced damage. Even -- Well, 


it’s not Pu 238 but so to support the slow 


clearance, yes, it’s sticking but there are -- 


it is going to become chemically more soluble, 


a little bit over time. It’s not like 


plutonium 238 which (unintelligible). But 


there are damage -- there is damage occurring. 


It just doesn’t sit there. 


 DR. MAKHIJANI: I had a -- sorry. I had a 


question about figure 3 in your approach dose 


reconstruction, page 5. 


 MS. MUNN: I don’t see 3. 


 DR. MAKHIJANI: I had a question about figure 


3, page 5. And I see that Hanford 1 curve 

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crosses the four types -- 


 DR. NETON: Right. 


DR. MAKHIJANI: -- in less than a year. 


DR. NETON: Right. That’s what I -- I talked 


about earlier, that when you approach a year 


the factor can be slightly higher than four. 


We believe in those scenarios we would be 


assigning a chronic intake scenario anyways if 


it were not a known incident. But we would 


monitor that as a chronic exposure. 


 DR. MAKHIJANI: Okay. I didn’t relate our 


discussion to that figure. Sorry. 


 DR. WADE: Okay. Are we ready to move on? 

 MS. MUNN: I believe so. 

 DR. WADE: Maybe just a brief sort of reminder. 

Don’t put a call on hold. Don’t do anything 


unusual with this. Please keep your phone 


muted if possible. And let’s continue. 


SUPER S


 DR. ULSH: Before we leave this issue I’d like 


to ask all the members of the working group and 


Mark in particular, where are we with this 


super S issue now? I mean the action item on 


the matrix was that we would provide -- NIOSH 


would provide to SC&A and the Board TIB 49 and 

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supporting data. We have done that. What goes 


in the matrix now in terms of what’s the next 


action? 


SAMPLE DR’S


 MR. GRIFFON: Right. I think -- I think the 


action is -- is that sample DR’s is -- is what 


we’re down to now I think. 


 DR. ULSH: Okay. 


 MR. GRIFFON: And that should come through the 


evaluation process I believe, through your 


evaluation report or in association with the 


evaluation report. 


 DR. NETON: Right. It would be a supplement to 


the evaluation report. 


 MR. GRIFFON: Yes. Right. But I think you 


satisfied the action here except for the 


partial DR’s --


 DR. ULSH: Okay. 


 MR. GRIFFON: -- listed parenthetically there. 


 DR. ULSH: Okay. Thanks. 


 MR. GRIFFON: Can I ask one more thing, one 


more follow-up on this item? I was going to 


ask before and my phone went dead and I had to 


transfer to another phone but Roger, you 


mentioned the 200 people in the building, 25 

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cases with the significant lung burden I guess. 


Is there a write-up on the follow-up of all 


these cases or is there any kind of write-up? 


 MR. FALK: There were papers published in the 


first year or two but there has been no paper 


to my knowledge that has been -- that has been 


written describing the long-term follow-up. 


 MR. GRIFFON: Is that -- Is that paper on the 


O drive or available or has that been 


(unintelligible)? 


 MR. FALK: It is part of the O drive 


documentation. 


 MR. GRIFFON: It is a part of (unintelligible)? 


Okay. Anyone -- Lew, you wanted to say 


something? 


 DR. WADE: Well, I was just saying that the 


sample dose reconstruction will not be provided 


as part of a supplement. There will -- There 


will be information provided in addition to the 


(unintelligible). 


 DR. NETON: Supplemental to --


 DR. WADE: Right. But not as a supplement. 


 DR. NETON: -- but not as a supplement. 


 DR. WADE: Which has a formal meaning. 


 MR. GRIFFON: Yes. 

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 DR. WADE: Thank you. 


 MS. MUNN: So, Mark, I’m looking at all the 


actions under comment number 2, and with the 


exception of the DR’s it looks like they’re 


covered; am I correct? 


 MR. GRIFFON: Yeah, I think so. 1B -- we’ve 


discussed all these items, 1B and 1C, correct? 


 MS. MUNN: Right. Yeah. 


 MR. GRIFFON: So yes, I agree except for the 


sample DR’s unless anyone has any other 


comments there. I think that’s all of this. 


COMMENT 4


 MS. MUNN: That takes us to item 4. 


 MR. GRIFFON: Yup. 


 MS. MUNN: Comment 4. 


 DR. ULSH: Okay. I’d like to -- this is Brant. 


I’d like to direct your attention to the first 


handout that I provided which is the 27 


February Matrix Issues and NIOSH Responses. 


And if you look at page 2 of that document 


you’ll see a reiteration of the comment. The 


action item here is that NIOSH will provide the 


data and supporting references to support the 


assertions regarding the practices for 


adjusting plutonium, isotopic -- isotopic 

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ratios and americium in-growth. If you recall, 


we talked about this at the Boston Board 


meeting and the question came up -- I think 


Arjun asked the question about what happens 


when you start with aged plutonium from which 


the plutonium 241 has been removed and you 


might not expect any americium in-growth. All 


right. And Roger at that time stated that in 


fact at Rocky Flats the old -- the aged 


plutonium was blended with new plutonium. And 


so the action item is that we would provide 


documentation of that. We’ve done two things. 


The first, we’ve contacted three long-term 


former Rocky Flats workers and they’re -- 


they’re listed here in the second paragraph of 


the response. The consensus was that blending 


did occur and it was part of the routine 


process. A second track that we have pursued 


is that you’ll see on page -- pages 3 and 4 


there is a graphic here. This is a document 


that we have located. Page 3 is not really 


that informative. I included it for 


completeness. But if you look at page 4 


there’s a couple of points I want to make from 


this document. If you look at the very bottom 

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the first thing -- the first point I want to 


make, there’s a list of plutonium isotopes and 


you see the weight percent for each of the 


isotopes. And what you see there for plutonium 


241 the weight percent is .3684 percent. And 


that essential -- this document is from 1987 if 


I’m --


 MS. MUNN: Yes, ’85 through ’87. 


 DR. ULSH: Yes. And that matches pretty well 


with the plutonium 241 isotopic ratio that you 


observe in the Rocky Flats environmental impact 


statement from 1976 to ’78 which was about .36. 


So that that demonstrates is that over that 


time period the isotopic ratio was stable. So 


I think that that answers that concern. The 


other thing to note --


 DR. MAKHIJANI: Before you leave that, Brant, 


could I ask a question about that EIS? 


 DR. ULSH: Yeah. 


 DR. MAKHIJANI: Was the EIS based on -- on 


current measurements like this 1987 document or 


how was it prepared? 


 DR. ULSH: I’m going to defer to Roger on -- on 

that. 

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am presuming that it was from the material 


control documentation for the site. But --


But I do not know that for a fact. 


 DR. MAKHIJANI: Because just -- just, you know, 


for the record, EIS has contained a variety of 


types of information, some more reliable and 


some less reliable in my experience. And --


And I think this is a pretty big conclusion to 


base -- this document that you -- from 1987 


seems to be pretty clear where the -- when the 


measurements were made so one -- it -- it -- it 


seems clear that they were made on contemporary 


measurements. But since you need that other 


point I would have less confidence of this time 


without some -- some evidence that they were 


contemporary in these measurements. 


 MR. LANGSTED: Yeah, the -- in the 1980 EIS the 


-- the weapons mix was a fairly classified 


piece of information all through those years. 


And to declassify that I believe they took a 


average over a three or four-year period and it 


was I believe ’70 -- mid-’70s to late ’70s. 


And that number was published in the EIS and is 


referenced and that was the -- that was the 


number that this is based on -- 

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 DR. MAKHIJANI: Okay. 


 MR. LANGSTED: -- for that early period. 


 DR. MAKHIJANI: Which would be okay if it were 


from that period. 


 DR. GLOVER: One of the other items is that the 


Rocky Flats autopsy data tracks very well with 


the unbroken curves when you compare at the 


time of autopsy what the plutonium -- the 


americium 241 to plutonium ratios are. They do 


a very nice job of predicting the age of the 


plutonium and --


 DR. MAKHIJANI: Starting with this .36 percent? 


 DR. GLOVER: If you used the Rocky Flats 


defaults. 


 DR. MAURO: So the autopsy data for the 123 


cases --


 DR. GLOVER: Some of them are low precision as 


lung -- low activity. But the cases where you 


have reasonable precision in the measurements 


they do a good job of predicting. 


 DR. MAURO: So you didn’t see any surprises 


where it was just the plutonium 239 was there 


without the 241 --


 DR. GLOVER: That's correct. 


 DR. MAURO: -- or the americium? 

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 DR. ULSH: Okay. So there’s -- there’s another 


piece of supporting data. 


 DR. MAURO: I’ve got a related question. The ­

- The urinalysis work that we were just 


talking about and the approach that was laid 


out, let’s postulate that, yes, it’s 


bulletproof, works, solves the problem from 


high fired plutonium, the implications being 


that, okay, do we have -- do we -- I presume we 


have urine data across the board from very 


early continuing on workers? 


 DR. ULSH: Uh-huh. That's correct. 


 DR. MAURO: Do we need the chest count data? 


 DR. ULSH: Do we need it? 


 DR. MAURO: Yeah, if you’ve got the urine data. 


In other words -- In other words, what I’m 


hearing here is were the -- how many -- if you 


can do it reliably and in a claimant favorable 


way based on the model that you just developed 


for high fired plutonium, you basically -- you 


have your protocol. Then along comes the chest 


count data. You’re going to have that, too. 


And now, we -- we -- we’re discussing this 


issue. You made your case that the problem 


that we raised doesn’t really exist. So --

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But if it did -- but if it did exist, okay, 


assuming that for some reason we say, oh, we 


find something out later that says, no, no, no, 


no. We -- We found -- We believe that there 


are situations where we just have the -- the 


plutonium there by itself. Does that problem 


go away if in fact your urine approach, it 


works? 


 DR. GLOVER: It does. 


 DR. MAURO: Okay. 


 DR. GLOVER: I mean we talked about that the 


last --


 DR. MAURO: Yeah, that’s why I’m asking the 


question. 


 DR. GLOVER: In fact I thought this item was 


going to be annotated to essentially state -- 


 DR. MAURO: To say -- I wanted to hear that. 


 MR. GRIFFON: I need closure on it, too. 


 DR. MAURO: Yeah, I wanted to hear that. 


 DR. NETON: And I think that’s true. I mean 


given all your assumptions and caveats -- 


 DR. MAURO: I have a hard time with it. 


 DR. ULSH: The other point that I want to make 


before we leave this document, the handout on 


page 4 where it shows the plutonium isotopic 

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ratios per weight percents, there was some 


discussion about whether or not the assumption 


of 100 ppm americium was conservative. In 


other words, is there -- I think John might 


have asked, is there a plausible situation 


where you might have a lower -- lower americium 


content. And this document also provides some 


information along those lines. If you look at 


the top of page 4 there you see number 2, and 


there are several bullets that follow. And 


they describe the americium content at various 


stages of the process, and nowhere is it lower 


than 100 ppm. In most cases it’s higher. So I 


think that supports the value that we are using 


in the TBD. 


 MR. GRIFFON: What page is that? 


 DR. ULSH: This is the handout, Mark, that -- 


the matrix issue responses, and this is on page 


4. There’s a graphic there of a document I 


scanned in. And if you look at the bullets 


there below the number 2 -- 


 MR. GRIFFON: Yeah. Got it. 


 DR. ULSH: Yeah. So I think this lends some 


credibility to the number that we’re using in 


the TBD, 100 ppm, unless we know differently. 

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 DR. MAKHIJANI: Brant, in that -- in the second 


bullet from the bottom? 


 DR. ULSH: The waste stream americium content? 


 DR. MAKHIJANI: Yeah. How -- How do you 


handle that? Are the -- and maybe Roger can -- 


are the workers who were working with the waste 


streams, is that in their records so that you 


know they were working with americium 


concentrated sludges and waste streams and 


things? 


 MR. FALK: I really don’t know that that is in 


the workers’ files. 


 DR. MAKHIJANI: So how do you handle the waste 


stream workers? 


 MR. FALK: Would NIOSH like to answer that? 


 DR. NETON: I’m not sure what’s the question. 


I mean it certainly indicates there was 


approximately 200 parts per million americium. 


 DR. MAKHIJANI: No, that’s -- that’s in the 


plutonium stream. I think the question about 


the in vivo counting of plutonium streams seems 


to be answered --


 DR. NETON: Oh, okay. The salt waste -- 


 DR. MAKHIJANI: -- based on the --


 DR. NETON: -- the parenthetical explanation. 

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 DR. MAKHIJANI: And just looking at that 


parenthetical remark, because I think this has 


come up in some other context, is how do you -- 


how do you handle the dose reconstruction from 


the -- from the workers who were involved with 


the waste streams. 


 MS. MUNN: Well, if that information isn’t in 


the CATI, how do you know it? 


AMERICIUM 241


 DR. ULSH: I’m going to step out on a limb here 


and ask Dave Allen to correct me if I stick my 


foot in my mouth. What we are counting when we 


do a chest count, or let’s talk about the chest 


counts, is the americium 241 gamma. 


 MR. ALLEN: Right. 


 DR. ULSH: If that was in fact not a result -- 


 MR. ALLEN: We’re counting the americium 241, 


well, the -- the normal chest counting 


technique at Rocky Flats and most places is 


counting the americium 241 gamma and making 


some correction there for how much plutonium 


that -- that means. So using the 100 ppm 


basically we assume that there’s what, 1,000 


times that amount -- amount of plutonium in the 


lungs. So I'm not sure where you’re getting 

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at. If it’s a concentrated americium stream 


and we’re lung counting, we’re going to be 


overestimating the plutonium. 


 DR. ULSH: That’s the point I was hoping to 


make. 


 DR. NETON: But that -- But that begs the 


question I guess, just for the completeness, 


that we don’t have lung counting data 


throughout the operating history of Rocky 


Flats. 


 DR. MAKHIJANI: Or data for americium. 


 DR. NETON: Classified in that, well, yeah. 

 MS. MUNN: Was this not a wet process? And how 

--

 DR. NETON: Salt stream, yeah. 


 MS. MUNN: How -- How would the worker be 


ingesting these salts in any case? 


 DR. NETON: They were more than likely inhaling 


I think. It would be difficult to inhale from 


a wet waste stream. 


 MS. MUNN: Yeah. 


 DR. ULSH: Okay. I don't know if -- 


 DR. NETON: I think that’s just something we’re 


going to have to think of. It’s a good 


question and we need to -- we need to think 

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about that unless Roger has some insight he’d 


like to share with us related to that process. 


 MR. FALK: Well, what we’re talking about is 


the molten salt operation and that started 


probably late ’60s, early ’70s, so -- and so we 


did have the lung counter there. And the 


method of the lung counter is that there was a 


possible inhalation situation. The ratio 


monitors would get a sample of the 


representative type of the material and we 


would measure the parts per million in that 


sample for each lung count case. So we have 


that measurement and that is documented on 


report in the claimants’ files. So we -- So 


there shouldn’t be any real surprises there. 


And then the comment -- the comment might also 


pertain, well, now, what is the likelihood of 


the exposure to the waste streams. And that 


was fairly well contained but I don't know if ­

- but I don't know if -- if there was no 


possibility for that. But then that would have 


been measured by a loss of the containment 


also. 


 MR. GRIFFON: Roger, was there a predecessor to 


the molten salt process that would have 

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resulted in -- in kind of waste stream, or no? 


 MR. FALK: There were americium type of 


separations starting in the late ’50s in 


building 71 as part -- as part of the 


purification process for the plutonium. And 


yes, so there would have been that -- that 


component which would branch off during the 


chemical separation starting -- 


 MR. GRIFFON: Then I think the issue might 


still be on the table from that point. 


 DR. ULSH: Okay. I think -- I think we should 


maybe mark that down as an action item -- 


 MR. GRIFFON: Yeah. 


 DR. ULSH: -- that we can provide you some 


follow-up on pretty quickly. 


 MR. GRIFFON: Follow up on the other. And I 


agree with Jim earlier that, you know, we did 


add to the (unintelligible). In other words, 


you don’t need that. But, you know, this 4 was 


kind of an (unintelligible) on that, too. But 


I think to the extent this part might be a site 


profile issue but (unintelligible) americium is 


should --


 DR. ULSH: Okay. So we -- So we close out 


matrix issue number 4, action item 1 and add a 

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new issue about americium? 


 MR. GRIFFON: Right. 


 DR. ULSH: Okay. 


 MR. GRIFFON: I think that sounds agreeable to 


everyone. 


 DR. NETON: Yeah. I think this would be a 


separate issue --


 MR. GRIFFON: Yeah. 


DR. NETON: -- other than 4. I mean it really 


is not related to the lung count. 


 MR. GRIFFON: It’s really not related. We can 


have a new issue. 


 DR. NETON: It’s essentially an americium 


strain. 


 MR. GRIFFON: It’s a new issue within the 


matrix. 


 MR. FITZGERALD: Could someone restate the 


issue just based on what -- 


 DR. ULSH: I hope someone can. I don't know 


that I’m the best person to restate it. 


 DR. NETON: I think the issue is that there are 


-- there are time periods when the in vivo 


counter was not operating where americium was 


present in its purified form somewhere in the 


facility. I think that’s -- 

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 MR. GRIFFON: Yeah. How do you determine the 


presence of americium in its purified form 


prior to lung counting. 


 DR. NETON: Given that we have no americium 


uranium urinalysis -- 


 MR. GRIFFON: Right. 


 DR. NETON: -- or in vivo counting capabilities 


so it would be before the 1960’s time frame 


where this would be relevant. 


 DR. MAURO: If you did have a person that was 


exposed to the separated americium 241 and you 


did a chest count and you -- would you also 


assume that he, along with the americium the 


plutonium was there also and there -- thereby 


come up with some I guess unrealistic 


overestimate? Is -- In other words, I’m 


looking at -- or do you know when the person is 


working solely with the separated americium and 


therefore you know you’re not dealing with this 


-- that gray -- that gray area where you’re 


going to be tricked into thinking he’s got a 


very large plutonium burden? 


DR. NETON: I think there was a pretty good 


discussion by Roger earlier that we more than 


likely know where this person was working. 

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 DR. MAURO: Okay. 


 DR. NETON: Or especially if there were an 


incident, if you were working in that area. 


 MR. FALK: Well, you would also have the 


plutonium urine data too that would bound that. 


DR. MAURO: Well, what I’m hearing -- I was -- 


you never see anything in the urine for 


plutonium I mean. 


 DR. ULSH: If it’s super S. 


 DR. MAURO: Or S -- even is my understanding. 


Very often you don’t see it. 


 DR. ULSH: Right. 


DR. NETON: But we would assume a certain -- a 


certain detection limit and apply it. 


 DR. MAURO: Apply it anyway? Okay. Okay. 


 DR. ULSH: The other thing to maybe think about 


before we leave this issue, and Roger, maybe 


you can chime in and correct me if I’m wrong. 


But we did do gross alpha urinalysis in the 


early years and I think that americium 241 


would have been captured in that, correct? 


 DR. NETON: Yes. 


 DR. ULSH: So for the gross alpha measurements 


I think we would assume the most claimant 


favorable element for the dose reconstruction. 

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So this is a way to bound. 


 DR. NETON: Yeah, I think that’s right. We 


probably need to sit back and think about it. 


 MR. GRIFFON: Yeah, I think you might want to 


sit back and think about it. 


 DR. NETON: I always find it somewhat dangerous 


to start solving here. 


 MS. MUNN: Solving here. 


 DR. ULSH: That’s why Jim has to reel me back 


in when I start going out too far on a limb. 


 MS. MUNN: Just call it new issue 3. 


 MR. GRIFFON: Yeah, new issue 3. Back to issue 


4 though, we -- are we done with that? 


 MS. MUNN: Looks like it to me. Everybody 


happy where we are? I see nodding heads. 


 DR. MAKHIJANI: Yeah. Yeah. I think, yeah --


I can say we are. 


 MR. GRIFFON: Do you want to delve into issue 6 


before lunch? 


UNIDENTIFIED: I’m game. 


 MR. GRIFFON: All right. 


 MS. MUNN: Well, it’s brief. 


 DR. MAURO: Everybody checked out? When is 


checkout time by the way just to let everybody 


know about it? 

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 MR. GRIFFON: Brant? 


COMMENT 6, CALIBRATION


 DR. ULSH: Number 6, action item 1. The 


question here dealt with the justification for 


using the NTA film calibration factors for 


brass track dosimeters in the NDRP. I think 


this is discussed in one of the comments that 


I’ve seen they have sent over in the past week; 


is that correct? 


 MR. FITZGERALD: Yeah. The calibration issue. 


 DR. ULSH: Okay. 


 MR. FITZGERALD: That's correct. 


 DR. ULSH: Let me just get into it a little bit 


here. In terms of the glass track plates, 


these were conduct -- these were read by the 


Los Alamos Scientific Laboratory, LASL, and 


really there was never a question about the 


integrity or the validity of those reads. The 


NDRP was faced with a choice of whether to 


include the glass track plates or not to 


include them. They included them and applied 


the NTA calibration factor which increased the 


neutron dose estimates by a factor of about 


2.3. Keep in mind though that the original 


estimates from the glass track plates were not 

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in question. The NDRP just did this as a 


claimant favorable moderate overestimate. We 


don’t believe that it would be worthwhile to go 


back and back those out so that we could lower 


the neutron doses. So that’s our -- that’s our 


response. I don't know. 


 MR. FITZGERALD: Ron? Ron? 


 MR. GRIFFON: I'm not sure NDRP was addressing 


the claims. 


UNIDENTIFIED: Right. 


 MR. FITZGERALD: Ron Buchanan, are you on the 


phone? 


 MR. BUCHANAN: Yes, I’m here. 


 MR. FITZGERALD: Did you hear -- Did you hear 


the response? 


 MR. BUCHANAN: Yes. Now, the way I understand 


it there was only 10 to 18 of those neutron 


track plates used here prior to ’55/’56. And 


then -- then they started doing their own 


(unintelligible) in ’57/’58 time frame 


(unintelligible); is that correct? 


 DR. ULSH: I’m going to -- I’m going to defer 


to Roger on that. 


 MR. FALK: I believe that we successfully reread 692 of the glass plates ranging in years 

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from 1952 through January of 1957. And so that 


is the scope of the glass plates. And the 


difference between the original neutron dose 


which was evaluated by Los Alamos versus our -- 


our re-read plus -- plus the film calibration 


factor was as -- was as Brant stated a factor 


of 2.3 higher than the original. So the 


project had a choice. Do we go with the 


original or do we apply the neutron film 


calibration factor and get a overall higher -- 


higher neutron dose. 


 DR. MAKHIJANI: Okay. So what you’re saying is 


by applying the MDA calibration factor -- and 


was that the reason that you came up with this 


2.3 higher dose --


 MR. FALK: That was --


 DR. MAKHIJANI: -- than the calibration? 


 MR. FALK: That was an outcome of -- of the -- 


an outcome of -- of using the neutron film 


calibration factor on the glass plate of tracks 


read by our projects. Therefore management 


decided that -- that -- management decided to 


actually include the -- the -- the re-reads of 


the glass plate in the scope of the project. 


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plates? Now, I understand glass plates are 


more fragile than film obviously 


(unintelligible) than film and some of them 


were not -- were they in readable shape, most 


of them? 


 MR. FALK: Most of them were in readable shape. 


There were -- There were about, I don't know, 


30 or 40 of them that were not and therefore we 


did not modify those doses. 


 MR. BUCHANAN: Okay. So what you’re saying 


then is that apparently based on glass plates 


were more extensive (unintelligible) than film, 


NDA films which calibrating factors -- using 


calibration factors from the film that gave us 


(unintelligible) dose; is that correct? 


 MR. FALK: I'm not sure that I -- that I heard 


all of that but there were a couple 


differences. It turns out that -- It turns 


out that Los Alamos only read one square 


millimeter of -- of -- of the surface area 


whereas the project read ten square -- read the 


ten square millimeters of it so that was one 


improvement in the counting statistics as well 


as the application of the NTA of -- of the NTA 


film calibration factors. So both of those 

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were a factor. 


 MR. BUCHANAN: So I assume what you’re saying 


here is that in your opinion that the NDA 


plates, the doses recorded from them are 


correct. 


 MR. FALK: I don't know if they are correct but 


they are claimant favorable relative to the -- 


relative to the dose of record currently based 


on the original reads. 


 MR. BUCHANAN: Okay. Arjun, (unintelligible). 


 DR. MAKHIJANI: No. No, I think the -- the, 


you know, I guess the only question would 


relate to the original reads and -- and if 


there’s, you know, documentation that the 


original reads are okay then -- then I think 


the question would be resolved. But the 


specific question in regard to calibration 


would be resolved. I guess (unintelligible) 


shifted a little bit because I haven’t ever 


thought -- I hadn’t thought of going back to 


the original reads and I did not know the 


source of the differences so I guess you have 


documentation about the -- 


 MR. GRIFFON: Arjun, I can’t hear -- 


 DR. MAKHIJANI: I’m asking whether -- whether 

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the NDRP had documentation about the original 


reads and the protocols and how they were done 


and so forth. 


 MR. FALK: Yes, we -- we did capture a lot of 


that documentation from a trip out to Los 


Alamos. 


 DR. MAKHIJANI: Is that available like on the O 


drive or --


 MR. FALK: No, I do not believe that is on the 


O drive. 


 DR. MAKHIJANI: Yeah, I -- Yeah, I think -- I 


think, you know, but the specific question 


anyway has been addressed. 


 MR. BUCHANAN: It’s okay with me. 


 MS. MUNN: So we’re done with 6? 


DR. NETON: Done with 6. 


DR. ULSH: Okay. The --


 MR. GRIFFON: I’m looking at your other Word 


documents that you sent. Is number 6 addressed 


in this 24 March, 2006 Comments and Responses? 


 MS. MUNN: Yes. 


 MR. GRIFFON: Is that it? Okay. 


 MS. MUNN: That’s it. 


 MR. GRIFFON: We’ve discussed it like two or 


three times. If we’ve discussed all the 

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aspects of this why don’t we just scan through? 


 DR. ULSH: Let me look here, Mark, just to be 


sure. 


 MR. GRIFFON: Yeah. 


 DR. ULSH: We provided the OTIB 50. Let’s see. 


Okay. The justification for using NTA film 


calibration for glass track. That’s what we 


just talked about. 


 MR. GRIFFON: Right. 


 DR. ULSH: Let’s see. Oh, the other one was 


using one or two neutron calibration spectra to 


cover all neutron energy spectra at Rocky 


Flats. That is an issue that was raised in 


some of the later comments. 


 MR. FITZGERALD: Yes. 


 DR. ULSH: We’ll get to that if -- I’d like to 


defer that if possible. 


 MR. FITZGERALD: We -- We have a general --


 MR. GRIFFON: (Unintelligible) 


 MR. FITZGERALD: -- Mark, a general discussion 


of OTIB 50 which I just emailed you a copy of 


the draft from which the questions which Brant 


is referring to are derived. We were going to 


wait until the answers came back before issuing 


a final but I’m going to go ahead and circulate 

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a draft along with the answers. Brant told me 


to circulate the answer to separate questions. 


So we probably need an OTIB 50 discussion that 


would involve some of the issues coming out of 


that review. And we can do it anywhere you 


want but I would suggest after lunch. 


 MR. GRIFFON: Okay. All right. That’s fine. 


 DR. ULSH: Okay. Are we then ready to move on 


to matrix item number 7? 


 MR. GRIFFON: It might be -- is it time to 


break for lunch? 


 DR. WADE: There are a lot of hungry people 


around this table. All right. Why don’t we 


break for lunch and plan on being back at 1:00 


p.m. Okay. We’ll break the line now and then 


dial back in at 1:00. 


 MR. GRIFFON: All right. 


 DR. WADE: Thank you all. 


 MR. GRIFFON: Bye. 


 (Whereupon, a recess was taken from 12:00 p.m. 


to 1:05 p.m.) 


DR. WADE: For those of you on the phone, don’t 


put us on hold or don’t think you can switch to 


another line and do something else. We got 


music and we got all manner of things so, you 

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know, be very careful with how you deal with 


this open line. Again, as I said before, it’s 


important work and we want to have this vehicle 


available to us to do it. I think we’ve done 


wonderful work this past two days. So please 


help us preserve our ability to have these 


kinds of meetings and these kinds of calls by 


sort of policing your actions well. And now 


Ray’s going to give you his version of a public 


service announcement. 


THE COURT REPORTER: Okay. The audio-visual 


guy here said in order to prevent the 


recipients of our telephone from getting so 


much reverberation they had to turn these mikes 


down so he said speak close and very directly 


into the mikes. And we now have these handhelds so just make sure this green button is 


lit if you’re going to use one of these. And 


it should stay lit but if it goes off then hit 


the mute button and it should come back on. 


But just remember to speak directly because the 


volume had to be turned down. 


 DR. WADE: Okay. So let’s get back to it. We 


were on a roll this morning and let’s see if we 


can continue that well into the wee hours of 

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the night as we continue to work around the 


clock. 


 MS. MUNN: The wee hours being a couple of 


hours from now. 


PLUTONIUM TETRACHLORIDE CALIBRATION


 MR. GRIFFON: Yeah, I think we were on item 7, 


right? 

 MS. MUNN: Item 7. 

 DR. ULSH: Seven, action item 1. 

 MS. MUNN: Plutonium tetrachloride calibration. 

 DR. ULSH: This issue I think has been 

superseded by some of the comments that SC&A 


sent over in the past week. It really should 


have been that SC&A would review the article by 


Mann and Boss. They have done that and we have 


submitted some questions on that article which 


are included in the -- the other comment sets. 


So I would propose that we defer that until we 


get to those -- those other comments if that’s 


acceptable to everybody. 


 MR. GRIFFON: That's fine. 


 DR. ULSH: Okay. Oh, sorry. I think that is 


it for number 7. Number 9 is a big one on data 


integrity. 


DATA INTEGRITY
 
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 MS. MUNN: Yes. 


 DR. ULSH: The first action item talks about 


OTIB 50 and SC&A would review that. And I 


think that’s what Joe handed out this morning; 


is that correct, Joe? 


 MR. FITZGERALD: Yeah. We went ahead and did a 


review of OTIB 50. Ron, are you still on the 


phone? 


 MR. BUCHANAN: Yes, I’m here. 


 MR. FITZGERALD: Yeah, we were going to go 


ahead and integrate responses to the questions 


so the cart got a little bit before the horse. 


I went ahead and circulated the -- certainly 


the preliminary analysis and that with the 


answers to the questions is pretty much where 


we are now with OTIB 50. We did have some 


issues. We did respond to those issues so I 


think just so you have the context. You have 


the analysis as well of the answers to the 


questions. 


 DR. ULSH: So I -- I -- I think that perhaps 


the issues that are discussed in this are also 


included in the comments that we’ll be 


addressing a little bit later; is that -- 


 MR. FITZGERALD: Yeah. Yeah. 

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 DR. ULSH: Okay. 


 MS. MUNN: Are the items that are underlined 


and starred --


 MR. FITZGERALD: Oh. 


 MS. MUNN: -- of particular import to you? 


 MR. FITZGERALD: Actually I started emphasizing 


certain pieces of that not realizing that it 


would have to be copied. And when I tried to 


print it out on the PC over here in the 


business office the ink ran out. So in keeping 


with everything else we’ve gone through today, 


I decided, well, okay, you have the benefit of 


some of my scribbles. 


 MS. MUNN: Thank you. 


 MR. FITZGERALD: No other -- no other 


importance. 


 DR. WADE: Transparency in all things. 


 MR. FITZGERALD: That's right. 


 DR. ULSH: Action item number 2 deals with 


NIOSH’s efforts --


 MR. GRIFFON: Could you read -- I'm sorry, 


Brant. It’s a little hard now for me to hear 


you guys. 


 DR. ULSH: Oh, I'm sorry. 


 MR. GRIFFON: I don’t have the reverberation 

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any more but item -- item 1 is now deferred to 


 DR. ULSH: No. Well, yes. Action item 1 deals 


with SC&A’s review of OTIB 50 which they have 


completed, and they’ve submitted some questions 


based on that in this -- in the later comment 


sets that we’re going to talk about hopefully 


this afternoon. 


 MR. GRIFFON: Okay. So that comes up under 


what, one of the (unintelligible) at the end or 


 DR. ULSH: Yeah. 


 MR. FITZGERALD: Yeah, there’s one at the end. 


And Mark, just for your information I went 


ahead and emailed --


 MR. GRIFFON: Yeah, I have that. 


 MR. FITZGERALD: Fine. 


 MR. GRIFFON: Go ahead with number 2 then. I'm 


sorry. 


 DR. ULSH: Okay. Number 2 deals with NIOSH’s 


efforts to obtain Dr. Ruttenberg’s data. That 


does continue. I’m scheduled to visit with Dr. 


Ruttenberg in Colorado next week. But again I 


do want to reiterate as I did at the last 


meeting that we have realistic expectations 

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about what the Ruttenberg data might provide 


for us. I think that if we provide co-worker 


models that everyone agrees to the real value 


of the Ruttenberg data, and this is my 


speculation, would be that it would allow us to 


do perhaps more precise co-worker calculations. 


However, I don’t want anyone to have the 


impression that if we don’t get the Ruttenberg 


data we don’t have a -- an approach. That --


That’s certainly not accurate. The other thing 


 MR. GRIFFON: I’m trying to remember, Brant, 


how the Ruttenberg data had originally got to 


the table. 


 MR. FALK: It was a comment by SC&A. 


 DR. ULSH: I think it was a comment in SC&A’s 


review of (unintelligible); is that correct? 


 MR. GRIFFON: That you should consider that 


data? 


 MR. FITZGERALD: Yeah. And really it was in 


the context of the job categories that would 


enable perhaps a better fit on the modeling. 


-- I tend to agree with what Brant’s saying, 


that it’s a question of precision that -- that 


in a way you would be able to apply the model 


I 
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more precisely having the job categories that 


Ruttenberg has. 


 MR. GRIFFON: But it sounds like it’s probably 


not an SEC sort of issue. 


 DR. ULSH: Well, that’s my contention. I mean 


it’s not a --


 MR. GRIFFON: Right. 


 DR. ULSH: -- not a closed issue but -- 


 MR. GRIFFON: Right. 


 DR. ULSH: -- I don’t see it as an SEC issue. 


 MR. GRIFFON: Okay. 


 DR. ULSH: Okay. Can we move on to number 3 


then if --


 MS. MUNN: Uh-huh. 


 DR. ULSH: Okay. Number 3. Okay. This is one 


that, an SC&A action item that they were going 


to review our completeness of external exposure 


data. 


 MR. FITZGERALD: Ron, are you following on the 


action item? 


 MR. BUCHANAN: Yes, I’m following that. I do 


not have (unintelligible). 


 MS. MUNN: You’re breaking up. We can scarcely 


hear you. 


 MR. BUCHANAN: Okay. Can you hear me now? 

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 MS. MUNN: Better. 


 MR. BUCHANAN: I get a (unintelligible) of -- 


of external dose data. To kind of summarize my 


question on 1 and 3 of that sheet that I sent 


in, there’s some questions I’ve done other work 


on (unintelligible) posted data. I don't know 


if Arjun had done anything on that or not. 


 DR. ULSH: Ron, just for clarification, are the 


three questions that you’re talking about the 


ones that were sent over this past Friday? Is 


that what you’re talking about? 


 MR. FITZGERALD: Yeah. Yeah. He’s saying 1 


and 3 addresses the -- the comments on OTIB 50, 


two of them address the what are perceived as 


gaps perhaps in -- and 1 and 3 address some of 


those issues. So this is responsive to this 


particular item but that’s all we have at this 


point. 


 DR. ULSH: Okay. 


 DR. MAKHIJANI: This -- if you ask me, I have 


not looked at gamma dose or beta dose issues at 


Rocky Flats. I just looked at the internal and 


the (unintelligible). 


 DR. ULSH: So is it accurate to say that this 


action item has been superseded by the three 

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questions that Ron submitted? 


 MR. FITZGERALD: Well, from the standpoint of 


neutrons. I think we focused on NDRP and the 


neutron issue. We probably need to and owe a 


closeout on anything else that would be on the 


external side. I think the neutron issue is 


the big issue --


 DR. ULSH: Okay. 


 MR. FITZGERALD: -- that we were focusing on. 


I don’t believe that there are other pressing 


issues that we’ve identified to date so... 


 MS. MUNN: So from an action item point of 


view, 3 is actually still open? 


 MR. FITZGERALD: Yeah, but I think we just have 


to cross a T that, you know, we’ve identified 


neutron as the issue in that regard. But we 


probably need to get back to you and to NIOSH 


if there’s anything else on the external side. 


We don’t think so but we need to firm that up. 


 MR. GRIFFON: Can someone refresh my memory? 


What document were you reviewing that -- I know 


was (unintelligible) but (unintelligible) 


pretty conservative (unintelligible) data that 


NIOSH provided. What document is that, what 


date? 

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 DR. ULSH: Well, I don't know that we provided 


in one of our comment responses -- I think it 


was the responses that we provided for the 


Boston meeting. 


 MR. GRIFFON: Yeah, I think it was the Boston 


meeting. 


 DR. ULSH: There was a graph in there talking 


about how many people were monitored per year 


but I don't know if that’s the document that 


we’re referring to here. Is that? 


 MR. FITZGERALD: I'm not sure either. 


 MR. GRIFFON: (Unintelligible) 


 MR. FITZGERALD: That is a little murky but the 


only issue that we’ve addressed in terms of 


completeness is the neutron issue so maybe we 


need to go back along with NIOSH and just 


figure out where that, you know, that item sits 


and close it out by next session. 


 MR. GRIFFON: Yeah, I have to take a 


(unintelligible) to determine -- 


 MS. MUNN: Yeah, I thought that went back 


before Boston actually but... 


 DR. ULSH: Could be. 


 MR. BUCHANAN: Yeah, I don't know, I don't know 


where that came from. I’m not familiar with 

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(unintelligible) reviewing the 


(unintelligible). 


 MS. MUNN: You faded out toward the end. 


 MR. GRIFFON: I think this came out of the -- 


the document that, Brant, you sent before the 


Boston meeting, comments and responses for 


Boston. 


 DR. ULSH: Okay. 


 MR. GRIFFON: Well, I’ll try to track that back 


to you and get a better matrix. 


 MR. FITZGERALD: So maybe we should leave it as 


an action for us to work with, Brant, and just 


backtrack this thing and then come back with a 


-- a response. 


 MR. GRIFFON: Yeah. 


 MS. MUNN: Good. Think it over. 


 DR. ULSH: I guess the next action item is 


number 4 under comment 9, and that is the coworker data. I’d like to give you a little -- 


a brief update on where we are with that. We 


have CEDR data for both internal and external. 


We also have the site -- site database, HIS-20, 


and we are in the midst of comparing those two 


data sets. And the preliminary analyses look 


pretty good but we are still doing some QAQC on 

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both of those data sets. We anticipate having 


that up in fairly short order. 


 MS. MUNN: So it’s still an open item? 


 DR. ULSH: Yes, it’s still an open item for us. 


 MR. GRIFFON: Can you -- Can you just repeat 


that a little? You’ve got two databases that 


you’re --


 DR. ULSH: We -- We have both internal and 


external data from CEDR. We also have internal 


and external data from the site database, HIS20, that’s the name of the site database. And 


we are currently comparing the two to determine 


whether they match. And so far the preliminary 


analyses look pretty good but we are still 


doing some QC on -- on both data sets. 


 MR. GRIFFON: But -- But can I -- can I ask a 


question on -- on pedigree? I mean aren’t you 


using HIS-20? 


 DR. ULSH: I'm sorry. Using what? 


 MR. GRIFFON: Aren’t you using HIS-20 databases 


for the project? Wasn’t CEDR developed from 


HIS-20? Seems to me you’re validating against 


something that came after. 


 DR. ULSH: No, actually, Mark, what we’re -- 


what we’re doing, for the external I’m pretty 

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sure that we’re going to wind up using HIS-20. 


For the internal we have -- ORAU has developed 


a -- a draft TIB for us that used CEDR data and 


we are considering the time frame available. 


We’re trying to determine whether it makes 


sense to use the CEDR data and validate it 


against the HIS-20 or whether to 


(unintelligible). We’ve done some comparisons 


between the two and they look very similar. 


But that’s from the internal side. 


 MR. GRIFFON: And can you from a co-worker’s 


model -- I don't know if you could sense this 


at all. I don't think if we were after this 


but the question did come up about how -- what 


-- what fraction of potential claimants would 


require co-worker data to be viewed, sort of 


like we looked at at Y-12. It was a fairly 


large percentage though; I think we had the 


impression it would be a small percentage for 


the Rocky workers. Is that --


 DR. ULSH: Well, coincidentally I have some 


information hot off the presses from Matt Smith 


that we currently have two Rocky Flats cases on 


hold for co-worker data. 


 MR. GRIFFON: Okay. 

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 DR. ULSH: Out of about 1,000 claims -- over 


1,000 claims. 


 MR. GRIFFON: So there’s only two out of 1,000? 


 DR. ULSH: Well --


 MR. GRIFFON: Or is that something 


(unintelligible) true? Okay. 


 DR. ULSH: Right. There are two that are 


identified as being on hold for co-worker data. 


 MR. GRIFFON: But is it fair to say that it’s a 


much smaller fraction -- 


 DR. ULSH: I think it’s --


 MR. GRIFFON: -- that are required -- 


 DR. ULSH: I think that is fair to say, Mark, 


that it is a much smaller issue here at Rocky 


Flats. Okay. Action item number 5 unless 


anyone has anything else for that. Action item 


number 5 deals with a number of issues, blanks 


and zeros in the record. And let me see if 


there’s anything else here. Oh, neutron 


monitoring, readings found to be in error until 


the 1970s and the dosimeter chips were 


sometimes destroyed or lost during processing. 


I think, Joe, correct me, but I think all of 


these issues have been included in the new data 


sets that you sent over; is that accurate? 

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 MR. FITZGERALD: Yeah, the list and comments, 


yeah. 


 DR. ULSH: Yeah. Okay. So it might be, Mark, 


that this item has been superseded by the new ­

-


 MR. FITZGERALD: Well, the new one is -- is 


simply I think a consolidation -- 


 DR. ULSH: Right. 


 MR. FITZGERALD: -- an itemized list of the 


data integrity issues. Mark, you’re familiar 


with that one, the piece that Arjun originated 


that -- that we wanted to put together just so 


we wouldn’t lose all these various -- I think 


it was actually Dr. Ziemer who requested a sort 


of an itemized complete list of all the issues 


that were not only listed here but also 


included in the petition. So we have one place 


where all these issues were -- were listed. 


And that was the purpose of that piece. 


 DR. ULSH: Yeah, that’s a good clarification. 


Thank you. The list is new in that it just was 


delivered to NIOSH but not all the issues in 


the list are new. 


 MR. FITZGERALD: Right. It’s a consolidation 


of both the petition issues -- 

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 DR. ULSH: Right. 


 MR. FITZGERALD: -- as well as the issues in 


here. 


 MS. MUNN: So the statement that the 


allegations should be addressed in the petition 


evaluation remains outstanding? 


 MR. GRIFFON: Just to go back for a second. 


think I have -- there -- there is this 


document, Brant, that you developed following 


the Comments and Responses, for Bob. 


 DR. ULSH: Right. 


MR. GRIFFON: And on page 5 of that document 


it’s under response for number 9, question 


5.11.2, -- 5.11.2. There’s a -- There’s a 


response to (unintelligible) data and it’s 


titled that way (unintelligible) matrix 


(unintelligible) item. I think the idea was 


for asking me to look over that. 


 DR. ULSH: That’s action item 3? 


 MR. GRIFFON: That’s action item 3, correct. 


 DR. ULSH: Okay. Just to clarify. It’s not 


one of the handouts for today. It was the 


responses that I prepared for the Boston 


meeting. 


 MR. GRIFFON: Correct. 


I 
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 DR. ULSH: Both SC&A and I are laughing because 


it’s hard to keep all of these balls in the 


air. Okay. 


 MR. GRIFFON: Right. 


 DR. ULSH: So all of these issues I think in 


action item number 5 are included in the new 


list and we have addressed them in the 


handouts, and hopefully we’ll get to that a 


little bit later to discuss those responses. 


 MS. MUNN: So what we have today that we 


haven’t discussed yet is SC&A’s review as it 


applies to the SEC. 


 DR. ULSH: Review of --


 MR. GRIFFON: Wanda, I can’t hear you. 


 MS. MUNN: I was just trying to clarify in my 


mind that what we’re going to discuss later is 


SC&A’s review as it applies to the SEC petition 


in question -- review of these questions. 


 DR. MAKHIJANI: Ms. Munn, it’s because it’s not 


a review. It’s a -- It’s a -- what I did was 


simply go over issues raised by -- by Joe and 


Steve on the site profile and go through the 


petition and compile the issues that looked 


like data integrity issues and do a list. 


 MS. MUNN: Okay. 

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 DR. MAKHIJANI: As Dr. Ziemer suggested. 


 DR. ULSH: Okay. That takes us to action item 


number 6 I believe. There’s a NIOSH action 


item here that we need to research this 


question further and the question is NIOSH to 


follow up on inappropriate low energy photon 


detector correction factor that may have been 


used as stated in the 1993 DNFSB report. Jim, 


help me out. Where are we going to -- That’s 


another ball in the air that I -- 


 MR. LANGSTED: Yeah, Jim Langsted here. We’ve 


been researching this and trying to find more 


specifics on the issue and can’t find anything 


from the DNFSB on this subject. But what we 


believe it is was an issue that came up in the 


early days of the DOELAP accreditation process. 


They at one -- one time had a K-16 X-ray 


technique that they used for low energy photons 


and then they also had an M-60 X-ray technique. 


And it turned out there were some significant 


problems evaluating these two together and the 


DOELAP ultimately dropped the K-16 method. And 


we believe it has to do with that and the 


response of our dosimeters and the algorithms 


that were used to process this data. We’re 

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looking at that and we’ll have a -- an analysis 


on that available here shortly. 


 MS. MUNN: So it’s still open. 


 MR. GRIFFON: Okay. 


 DR. ULSH: Okay. Action item number 7; that we 


will determine the extent and nature of the 


criminal investigations and/or security 


investigations mentioned by the petitioner 


during the Boston working group meeting. On 


March 15th I sent a letter to Tony DeMaiori 


that is included in your handout on page 6, a 


copy of that letter requesting that he provide 


-- he mentioned in his comments that he had a 


number of these investigation reports in hand. 


And so we requested that he send those to us or 


just give us the citations so that we could 


search them down ourselves and to date we have 


not had any response on that. So I think 


that’s where we are with -- with this issue. 


 MR. GRIFFON: Tony on the -- on the phone? 


 DR. WADE: He wasn’t earlier. 


 DR. ULSH: He didn’t announce earlier. I don’t 


think he is actually. 


 MS. MUNN: No. 


MS. THOMPSON: Tony’s not on the phone right 

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now because he’s meeting with a person from 


(unintelligible) and Associates at his office. 


This is Jennifer Thompson. He received the 


letter and actually you will be getting a 


letter in response that he just sent yesterday. 


And she is picking up a work copy of the report 


and you have contact information as to how to 


get association reports. They’re not covered 


documents. He can’t really ask for 


(unintelligible) but you guys should be able to 


get copies of them from the DOE 


(unintelligible). 


 DR. ULSH: Okay. That’s great. If you can 


just give us the citations we’ll -- we’ll run 


them down. 


MS. THOMPSON: (Unintelligible) that you should 


be receiving. 


 DR. ULSH: Okay. Thank you. 


 MR. GRIFFON: Thank you. 


 DR. ULSH: Okay. Number 8, action item number 


8; NIOSH will demonstrate the reliability of 


bioassay and external database. I think we 


talked about that under co-worker. 


 MR. GRIFFON: I think that’s a --


 DR. ULSH: Oh, is this a different issue? 

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 MR. GRIFFON: Well, NIOSH is a different issue 


in that you -- you took (unintelligible) going 


back to the raw data. 


 DR. ULSH: Okay. So the issue is to go back 


from the HIS-20 database and compare it to the 


paper records? 


 MR. GRIFFON: Right. 


 DR. ULSH: Okay. 


 MR. GRIFFON: Or -- Or -- Or (unintelligible) 


as one of the possibilities that we have used 


for the Y-12 effort. 


 DR. ULSH: Okay. That effort also continues. 


It’s not closed yet. We haven’t found any 


problems yet but I -- I don’t want to say that 


our analysis is completed. 


 MR. GRIFFON: I mean do you know if there is 


raw data available though or are you 


(unintelligible) been able to find that much? 


 DR. ULSH: There is raw data available. Jim, 


how about if I defer to you and you can talk 


about what -- what records are available and 


the -- the claimant files. And Craig Little 


might also have some input to provide on that. 


MR. LANGSTED: Okay. I was dozing. No, I 


wasn’t dozing off, no, sorry. In -- In terms 

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of the -- the comparison between the electronic 


database and the -- the bioassay and the 


external dosimetry data, in terms of external 


dosimetry the Kaiser Hill as they pulled 


together the claimant files did do a QC check 


between the electronic data and the data that 


was in the claimant’s health physics printed 


file. And that data was -- was carefully 


checked and there was a -- a QC sheet that was 


generated as that happened. And so all the 


files that have been sent over for claimants 


have been checked in terms of external. To 


take that one step further back to the original 


laboratory --


 MR. GRIFFON: Can I ask you just -- just to 


stop there? I'm sorry. That -- That 


comparison of working in claimants’ files 


versus working in a database, what’s in the 


claimant’s file, is that -- I'm not sure with 


Rocky Flats but is that a (unintelligible) on 


the database? I mean or is it -- or is there 


another source record? 


 MR. LANGSTED: Both the print -- both the 


printout from the electronic database and the 


records that were generated at the time and put 

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in the workers health physics file are provided 


for the claimants. 


 MR. GRIFFON: Okay. Okay. Because I imagine 


printouts would (unintelligible) pretty well. 


I was hoping that the others would be a more 


useful check. 


 MR. LANGSTED: Yes, one would -- yeah, one 


would help the printout -- would join up with 


the electronic, exactly. Exactly. And it 


turns out the printed records that were in the 


file, and as I -- I talked about at Boston, 


Rocky Flats was their primary source of record 


keeping for health physics records was the 


printed file and the -- the data that went into 


that printed file. The electronic database, of 


course, came on later on as computers became 


available. But -- And a lot of work has gone 


into that electronic database so we’re fairly 


comfortable with using that electronic database 


to generate the co-worker data and it -- 


 MR. GRIFFON: Is there any kind of rolled up 


(unintelligible) or (unintelligible) you 


couldn’t get (unintelligible) matched pretty 


well. And there’s a letter that goes along 


with the -- a QC letter. Are there any sort of 

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roll up reports that (unintelligible) and X 


number of claimants processed and we, you know, 


we -- here’s our QC reports and sort of summary 


of the records (unintelligible) database 


testimony. 


 MR. LANGSTED: No, Kaiser Hill did not keep a 


tally of --


 MR. GRIFFON: Right. 


MR. LANGSTED: -- of how accurate that was. You 


know, in retrospect that would be a nice piece 


to have here. What we do have is the next step 


back in that process for external dosimetry. 


Craig Little will talk about some analyses that 


he has done on some of the records. And this 


was actually going back to the original 


laboratory worksheets and comparing those with 


the data that’s in the health physics file now. 


Another -- Another link in the chain I guess. 


And he -- he took a look at that data and has 


some material we can go over here when you guys 


think that’s appropriate. 


DR. ULSH: That would be now. 


 MR. LANGSTED: Okay. 


 MR. GRIFFON: (Unintelligible) 


 MR. LANGSTED: Let me pass the -- Let me pass 

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the microphone on to Craig. 


 MR. LITTLE: What we did over the -- pardon me 


-- over the last month was we looked at scanned 


in data sheets, laboratory -- laboratory data 


sheets and pulled data sheets that corresponded 


to claimants. And we went back to the -- it’s 


a scanned in -- scanned in file of a -- of a 


handwritten data sheet. We went back to -- we 


found about 2,800 pages of those and we went 


through those and compiled over 400 person 


quarters or worker quarters of data if you will 


where we have a handwritten data sheet that’s 


complete for a quarter; and we compared that to 


-- to the data that’s in the -- that’s in the 


claimant file in -- either in the HIS-20 or the 


-- it’s a computer printout that’s part of the 


data file. And most of the cases, and I would 


-- in every single case where we found a 


complete match of a quarter or an annual -- an 


annual case the claimant file either matches 


exactly or has a larger number than the number 


that’s found in the -- in the beta gamma 


laboratory worksheet. But the difference is 


data that’s neutron data that we haven’t been 


able to find the -- the handwritten data sheet 

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for yet. And that’s our -- that’s our 


presumption anyway but it -- but it -- And 80 


or 85 percent of the cases we -- where we found 


complete annual data sets, the data match 


exactly. And the remaining 15 percent or so 


they don’t match and the -- and the missing 


link if you will is neutron data because the 


claimant data file, that is the data that’s in 


the claimant’s file is a -- is a larger number 


than the number that I found which simply means 


that there’s some -- some dose that I haven’t 


found a piece of paper to represent yet. 


There’s no evidence of any systematic bias or 


anything of that nature. And we tried to find 


doses ranging -- well, we didn’t search for 


doses exactly. We just searched -- we randomly 


pulled -- pulled claimant files if you will, 


and I did this for ease of use if you will. 


-- I pulled claimants from a number of 


different last names starting with A and 


working down through W. And -- And just then 


tried to go through the data for the these -- 


the periods that I had which were mostly mid­

’60s, late ’60s, and pulled -- pulled 


corresponding handwritten data sheets, entered 


I 
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those into a spreadsheet and then did -- simply 


did a calculation to show that the numbers were 


the same number. So... 


 MR. GRIFFON: Did -- Did you write this up or 


is this written up anywhere? 


 MR. LITTLE: It’s not yet. We’re still sort of 


in process on it. But we can get it written up 


fairly soon. 


 MR. GRIFFON: Sounds very useful, yup. 


 DR. ULSH: Okay. Unless anyone has anything 


else to add that’s action item number 8. 


 MR. GRIFFON: What do you hear on the internal 


dose? That was external. Is there anything on 


the internal side? 


 MR. LANGSTED: Internal dosimetry records are 


somewhat more problematic. The laboratory -- 


the basic laboratory data was not or could have 


been archived but there has been no effort to 


pull that data and compare it to what’s in that 


database. The laboratories have changed over 


the years and -- and data has come in from 


various forced. We have some documentation 


discussing how the data came into the database, 


you know, and as the years progressed 


laboratories started to submit electronic 

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deliverables that were then put directly into 


the -- the database. But that is a larger 


effort over -- over multiple years and we don’t 


have any QC data available on that issue. 


 MR. GRIFFON: Well, I guess -- I mean it’s 


still an open item I would say, yes. I mean is 


there any -- any help with (unintelligible) or 


anything like that maybe you could pull for 


summary statistics? 


 MR. LANGSTED: Well, the -- the worker -- the 


health physics file, the printed file -- does 


it have the bioassay? 


 MR. LITTLE: Some of the claimant files do. 


 MR. LANGSTED: Yes, the claimant files do have 


data in there and we could do a comparison 


between that and the -- the computer file 


similar to what Mr. Little did with the 


external data. 


 MR. GRIFFON: Okay. And again I’m assuming 


that the (unintelligible) printout of each one. 


 MR. LANGSTED: I'm sorry. Say that again. 


 MR. GRIFFON: I’m assuming that for all sources 


that you (unintelligible) HIS-20. There 


wouldn’t be a printout of data. 


 MR. LANGSTED: Correct. 

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 MR. GRIFFON: In the person’s file. 


 MR. LANGSTED: Yes. What’s in -- what’s in the 


person’s file predates the HIS-20. 


 MR. GRIFFON: Okay. 


 MS. MUNN: That’s in addition -- that’s a new 


item for me, Mark. I only -- I only had the 


external. 


 MR. GRIFFON: Oh, so (unintelligible) external. 


 MS. MUNN: Right. Okay. Thank you. 


 DR. ULSH: Okay. So we’ll put that down. 


 MR. GRIFFON: Okay. We’ll leave that open and 


-- and ongoing on external but it sounds like 


you’ve made some progress in that discussion. 


Okay, Brant. Sorry to cut in there. 


 DR. ULSH: No, no. That’s all right. 

 MS. MUNN: Takes us down to new issues. 

 DR. ULSH: Takes us down to at least on -- on 

the matrix that you circulated, Mark, from the 


February 27th meeting this is new issue number 


1. 


 MR. GRIFFON: Right. 


PENETRATING DOSES PRIOR TO 1976


 DR. ULSH: And this was the roll up of the 


penetrating doses prior to 1976. And the 


comment was that it is not clear how the 

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neutron and photon doses will be determined 


from the roll up dose. This is also an issue 


that is reflected in the new lists that contain 


both new and old issues so I think that we’re 


going to get to that when we cover some of the 


-- cover the responses to the -- to the new 


list. 


 MR. BUCHANAN: Yes. This is Ron Buchanan. The 


(unintelligible) 


 DR. ULSH: Ron? Ron, it’s difficult to hear 


you again. Can you get closer to the phone? 


 MR. BUCHANAN: Yes. New item number 1 has 


pretty much been answered, you know, 


(unintelligible). The only (unintelligible) 


for 1970 (unintelligible). 


UNIDENTIFIED: That’s in the questions? 


 DR. ULSH: Right. That’s in the questions that 


SC&A sent over so we’ll -- we’ll cover those in 


-- in due course. 


ALGORITHM
 

New issue number 2 has to do with the problem 


with the algorithm and this was a -- an SC&A 


action item on this. 


 MR. FITZGERALD: Actually at the Boston meeting 


we got an explanation and I think the -- the -- 

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the very last line we would continue to review 


that in the context of the overall review. I'm 


not sure that it was really an action item per 


se. I don’t think there was any disagreement. 


We just figured we would leave that open in 


terms of any other issues that would come out 


of our NDRP review. But I don’t think there’s 


any new issue. Ron, do you have anything on 


issue 2? 


 MR. BUCHANAN: Yes, on issue 2, we discussed 


that I think (unintelligible) and we feel 


(unintelligible) evaluating it both ways, both 


(unintelligible) and neutron is claimant 


favorable. I don't think neutron 


(unintelligible) on that. 


 MR. FITZGERALD: Okay. That’s what I thought. 


Okay. Thank you. 


 MR. GRIFFON: I think we can pull it up and 


close it out. 


 MR. FITZGERALD: Yeah. 


 MR. BUCHANAN: I agree with you 


(unintelligible). 


 DR. ULSH: And that takes us to the end of the 


February 27th matrix. Mark, you’re kind of the 


emcee here. 

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 MR. GRIFFON: Well, you lost me. You deferred 


so many that I'm not sure where we are. But I 


think we’re deferring them mostly because it’s 


little, right? The --


 DR. ULSH: Yes. There are two new sets of 


responses. One is dated 21 March, 2006 and one 


is dated 24 March, 2006. I would propose 


unless you want to do something different that 


we just walk through those. 


 MR. GRIFFON: Yeah. What I -- What I may do 


just to keep with our format, I may try to add 


these issues into the matrix. 


 DR. ULSH: Okay. 


 MR. GRIFFON: And roll up -- I think some of 


them will be removed from some areas and put 


into these new areas. I do want to keep these 


items in there. I should say also I think the 


-- were all these comments in -- in response to 


the list of issues generated by Arjun through 


reviewing the petition; is that correct? 


 MR. FITZGERALD: This is the longer 


consolidated list. I mean is your piece 


responsive to that longer list or to the 


original matrix list of the integrity issues? 


 DR. ULSH: There were -- okay, I gave three 

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handouts. The first one, the 27 February 2006 


Matrix Issues was our responses to selected 


items from the matrix that we just covered. 


Then we received 17 -- a list of 17 concerns 


this past Wednesday and this handout contains 


our responses to those. 


 MR. FITZGERALD: Which is affirmative to that 


question you just had, Mark. 


 MR. GRIFFON: Okay. 


 DR. ULSH: Sorry. The short answer is yes. 


 DR. NETON: What is this one then, 24th? 


 DR. ULSH: Twenty-fourth is three questions 


that I guess Ron Buchanan sent. 


 MR. FITZGERALD: Ron Buchanan, as part of OTIB 


50, came up with three issues which are 


actually identified in his analysis and that 


was the preliminary analysis I circulated today 


and emailed to you, Mark. And these three 


issues were the ones that were highlighted in 


particular in that review. And I mean Brant 


has passed around answers or responses to those 


three issues. 


 DR. ULSH: Yeah, that’s the 24 March 2006. 


 MR. BUCHANAN: Yeah, this is Ron. I want to 


clarify about OTIB 50. We didn’t really feel 

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there were necessarily a lot of SEC issues. 


However, dropping out of all the neutron 


documentation, the -- the TIB, the 


(unintelligible) and OTIB 50 were three issues 


I felt that we need to address from an SEC 


point of view. And those are the ones we 


listed as the three main questions and I guess 


your date is the 24th of March on that. The 


OTIB 50 itself, any comments on that was mainly 


a site profile issue. The three questions are 


more the SEC type issues. 


COMMENT RESPONSES, MARCH 21, ‘06


 DR. ULSH: So we’ve got two sets of comment 


responses to go through, Mark. Do you have any 


preference? Shall we just go in chronological 


order? 


 MR. GRIFFON: Yeah, that -- that’s fine. 


 DR. ULSH: Then I would direct you to the 


handout titled “21 March, 2006, SC&A Comments 


and NIOSH Responses,” and we’ll just walk 


through. Comment number 1 dealt with the zero 


entries in the dose record when badges were not 


returned. That was a carryover from matrix 


comment number 9. And there were two periods 


of concerned, before 1964, and 1964 and after. 

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And in the response that you see on page 2 of 


my handout I give an explanation. Let me just 


walk you through. Before 1964 a blank 


indicates that the worker was not monitored. 


On the other hand a zero before 1964 indicates 


that a worker was monitored but there was no 


positive recorded dose. Now, in both of those 


situations we have methods for dealing with it, 


either through applying missed dose or 


unmonitored dose using the co-worker data if 


necessary. And then the time period of 1964 


and after a blank or a zero could -- could 


indicate a period when a badge wasn’t returned 


at the scheduled badge exchange and Jim 


Langsted talked about that at the Boston 


meeting. Occasionally workers would miss badge 


exchanges. Perhaps they were sick on the day 


they were supposed to turn it in. Maybe they 


just forgot. But in any case they would 


continue to wear that badge for another badge 


exchange cycle. When the badge was turned in 


it was read and the recorded dose would be 


assigned to one badge quarter. I don't 


remember if it was the first or the second. 


 MR. LANGSTED: Second. 

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 DR. ULSH: The second badge exchange cycle. 


For the other -- the first badge exchange cycle 


they could put a blank in. Or if the computer 


programs at the time required it they could 


have entered a zero. In either case NIOSH 


would handle it by treating it as missed dose 


because there was a continuous badge. I mean 


the worker was badged throughout the entire 


period so we would treat that as a missed dose 


in either case. A zero entry could also 


indicate -- after 1964 it could indicate that 


there was no positive recorded dose on the 


badge. And if that’s the case then we would 


simply assign a missed dose. Now, there was 


another question about no data available and 


what that means when it shows up in the 


dosimetry records. And what that could mean, 


either a badge was not turned in or it was 


turned in and there was a problem with the 


badge. And there are a number of situations 


that constitute a problem with a badge, a 


suspect badge reading. When that happened the 


internal -- the dosimetry staff conducted an 


investigation. Things that could lead to -- 


could have triggered an investigation like this 

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would be a suspect high badge reading and there 


are a number of things that could lead to that: 


presence of contamination on the badge, 


detergents, solvents, hair, body oil. When 


those get on a TLD crystal and the crystals are 


read can lead to an anomalously high reading. 


The results of those investigations -- oh, the 


most obvious answer, too, is the high reading 


could be real. It could be the worker received 


a high dose. When -- When a reading was 


suspect this investigation would commence and 


the results of this investigation would be 


placed into the worker’s health physics file. 


However it may not have been communicated to 


the worker. So from the worker’s standpoint 


they could have turned in a badge, gotten back 


a report saying no data available, and, you 


know, it may not be obvious to the worker what 


had happened here. So that is -- is what we 


have when we have --


 MR. GRIFFON: Two questions on that, Brant. 


 DR. ULSH: Okay. Shoot. 


 MR. GRIFFON: That procedure that was 


formalized, what year was that procedure? 


 DR. ULSH: It was in the ’80s. Jim, do you 

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have the date? 


 MR. GRIFFON: ’88? 


 DR. NETON: Those are -- Those are ’90s. 


 DR. ULSH: The procedures that the internal or 


that the dosimetry section used, Mark, weren’t 


formalized until -- formalized into the form of 


a procedure until those documents that you see 


there but they were followed earlier than that. 


I mean they were followed in the earlier time 


period so they didn’t put them all together 


into a procedure until that date. 


 MR. GRIFFON: But the ones you listed there 


were -- what years were those? It doesn’t say. 


 MR. LANGSTED: Those are 1990 -- sometime in 


the ’90s. 


 MR. GRIFFON: Yeah. 


 MR. LANGSTED: On that subject, in the ’80s if 


you look two pages forward on page 4 there’s a 


diagram. And that comes from a set of 


operating procedures from 1983. And in that 


procedure things were not as formalized but 


there is a section in that procedure that 


instructs the technicians to take anomalous 


readings to the supervisor for resolution. 


 DR. ULSH: Yeah, there’s a Link and Pennock 

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reference that’s listed in the caption for 


figure 1. 


 MR. GRIFFON: They also -- in looking at the 


petition I do recall a specific allegation that 


this practice or concerns about this no data 


available when individuals felt that they were 


in a fairly high exposure area. And I wonder 


if you -- that was part of the petition package 


it might be useful to track a very specific 


case back to the (unintelligible) file and see 


if in fact that this procedure was followed. 


don't know if there’s other specific case 


number that can be tracked and say yes, it did 


work and it didn’t work. Since there was a 


specific allegation in the petition I think 


it’s worthwhile to -- we do have the specific 


example given in the petition. 


 DR. ULSH: Okay. So we’ll put -- we’re putting 


that down as an action item, Mark. 


 MS. MUNN: So let me understand correctly. In 


the case where you had perhaps less than an 


attentive employee -- 


 DR. ULSH: I'm sorry. Could you repeat that? 


 MR. GRIFFON: I can’t hear. 


 MS. MUNN: You have a situation where you have 


I 
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less than attentive employees who do not see 


that their film badges are rotated on the 


regular basis that should be. There is an 


excellent possibility that their dose will be 


overestimated by whatever you consider the LOD 


of that badge to be for as many times as they 


failed to rotate their badge. 


 DR. ULSH: It is correct that we would apply 


the missed dose to each -- let’s say a worker 


wore his badge for three badge cycles, which I 


think would be unusual -- 


 MS. MUNN: Yeah, it would. 


 DR. ULSH: -- but let’s just say that it -- 


that it happened. What you would essentially 


have is the recorded -- the dose -- the dose 


that was recorded on the dosimeter, the film 


badge or the TLD, would be recorded in the 


third exchange cycle. For the first two 


exchange cycles we would apply missed dose so 


yes, that would be claimant favorable. 


 MS. MUNN: Okay. 


 MR. GRIFFON: And at least that’s as it’s 


described. 


 MS. MUNN: At least what? 


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I 

at least the way you’re characterizing it I 


agree that would be claimant favorable. 


think we’ve heard, you know -- I think we 


(unintelligible) you know. 


 MS. MUNN: Considerably more than that, you 


know. 


 MR. GRIFFON: Make sure we (unintelligible). 


think it’s more than claimant favorable. The 


one scenario I remember was the 


(unintelligible) three quarters out of six and 


each one of those or he -- he claimed that 


there were high exposures. I think he was a 


radium technician. He claimed there were the 


highest dosed area and each one of those 


(unintelligible) didn’t have data -- no data 


available. Now, (unintelligible) important. 


But I think we have to follow up on this. 


 DR. ULSH: Okay, Mark. So the action item that 


-- that -- that we go forward with is to track 


back and make sure that this -- demonstrate 


that this procedure actually occurred. 


 MR. GRIFFON: Or if possible try to find 


specific examples. 


 DR. ULSH: Oh, some examples. Okay. 


 MS. MUNN: I got the impression Mark was 


I 
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particularly interested in the one case where 


the claimant maintained -- 


 DR. ULSH: If -- Mark, I can tell you if -- if 


that situation deals with a claimant it will be 


fairly easy for us to do I think. If it’s not 


a claimant I don't know that we’ll have access 


to his records. 


 MR. GRIFFON: Yeah. I'm not sure about that. 


 DR. MAURO: Excuse me. This is John Mauro. So 


in the case where there was a recording of no 


data available the position is that the policy 


was that that probably was some malfunction of 


the readout. You had mentioned that you would 


-- you would read it out; there would be some 


kind of unusually high reading that -- that 


sort of just didn’t seem to make sense. I know 


this is a great concern to the petitioners. 


 DR. ULSH: Yes. 


 DR. MAURO: Now, if you were to run this to 


ground -- in other words, if I was a petitioner 


and you were to tell me that, well, no, no, no, 


it wasn’t that we just pushed that aside. We 


have reason to believe that in fact it was a 


false high reading. I guess how would you go 


about doing that? Would you go to, for 

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example, other data for where he was and that 


perhaps area monitors? In other words, how do 


you convince a claimant or a petitioner that in 


fact he did not get that dose, that it was a 


scurrilous high result? What would be done to 


-- convince me, for example, if I were that 


person. 


 DR. ULSH: Well, we could refer to the 


procedures that we’ve referenced here that -- 


that direct the dosimetry group for when this 


investigation would be triggered and what the 


outcome would be. We could also look it it’s ­

- again, if it’s a claimant -- 


 DR. MAURO: Yeah. 


 DR. ULSH: -- we could also look in the 


claimant’s record at an investigation report 


that should be included in there. 


 DR. MAURO: The main reason I bring this up is 


from previous meetings this was -- this was a 


hot topic. 


 DR. ULSH: Yes. 


 DR. MAURO: And the degree which we could 


really run this to ground to the point where 


the petitioner would feel convinced that yes, 


in fact your answers are -- make sense. I --

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I want to just bring our attention to this one 


item because I know it’s sensitive. 


 MR. GRIFFON: Yeah, I’ve heard exactly 


(unintelligible) John, because it most 


definitely is. 


 DR. ULSH: So the action item is to show a few 


examples where this occurred, or the cases 


we’re presenting it actually is true. 


 MR. GRIFFON: Track specific examples where 


(unintelligible) 


 DR. ULSH: Okay. I’m looking at my guys and I 


think we can do that but I think Arjun has -- 


 DR. MAKHIJANI: Yeah, I have a little bit of -- 


of a question on this. I think the explanation 


that you’ve given in terms of somebody not 


handing their badge in because they were sick 


or not there that day and the badge being read 


in the next cycle probably applied to many of 


these cases. But the difficulty here is given 


the allegation that along with affidavits and 


specific examples and in one case specific 


numbers of radiation fields, the -- the problem 


is to show that it was only the truly odd 


exception that you could deal with on an 


individual dose reconstruction, that this 

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wasn’t -- that there isn’t a systemic problem 


of fabrication. I think through the petition 


and the affidavits there’s a suggestion of 


fabrication and I’m wondering -- that’s the -- 


so this is -- this is probably a problem and 


this procedure is a good way to deal with it 


and I don't have a problem with that. It’s --


It’s knowing that the zero or blank record have 


all characterized or most -- almost all 


characterized with this. That’s, I think, a 


little bit more difficult. 


 DR. ULSH: Well, the fabrication issue is dealt 


with in a later comment. 


 DR. MAKHIJANI: All right. 


 DR. ULSH: How about if we revisit that after 


we’ve --


 DR. MAKHIJANI: Sure. 


 DR. ULSH: -- talked about that and see if 


there’s still -- So that’s the explanation at 


least that we’re providing. The action item is 


for us to show some examples of this. Okay. 


Comment number 2. This deals with an 


allegation by or insertion let’s say by the 


petitioner that tips fell out of the TLD’s and 


readings were not included in workers’ records. 

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141 

And they go on to say that they fell on the 


floor and were lost and were hence never read. 


This is an affidavit that was in the petition 


and it was related in this -- this comment 


here. In our response we say that it is 


possible that these crystals were read before 


they were dropped. However, it is also 


possible that they were dropped before they 


were read. Now, the -- the question is what do 


you do in that case. And if you look at page 4 


of the handout there’s a diagram. Jim referred 


to this earlier. It shows the TLD system at 


Rocky Flats and what you’ll notice is that 


there are duplicate chips. There are, for 


example, two TLD 600s. There are two TLD 700s. 


If one of those chips was lost, as sometimes 


happened, the dose could be reconstructed, 


could be read from the remaining chips. So, 


yes, it is possible that some chips were lost. 


However, this does not prevent the badge from 


being read. So that’s our response on that. 


 MS. MUNN: Is that okay? 


 DR. ULSH: So Mark, where do we go with this 


item? Is it --


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these responses today so -- 


 DR. ULSH: Well, I understand. 


 MR. GRIFFON: Yeah. I would say that it 


certainly (unintelligible) your response. But 


 DR. ULSH: Could we put that NIOSH has 


responded and someone will review? 


 MR. GRIFFON: Yeah, NIOSH has responded -- you 


provided a response. And the action 


(unintelligible) NIOSH from this standpoint 


(unintelligible) 


 DR. ULSH: Comment number 3, it says hair and 


body oils on the TLD chips cause inaccurate 


readings. I would agree. When you had 


contamination on the crystals it could result 


in anomalously high readings. That is 


certainly true. Again, when there is a suspect 


reading on a -- on an individual chip we have 


duplicate chips. And so I would answer it very 


much the same way as I did the previous one and 


that is that we could use the other remaining 


chips to get a dose estimate from that badge. 


 MR. GRIFFON: The only thing I -- I would say 


if this comment is true is you are referencing 


these procedures quite often it seems. 

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143

 DR. ULSH: Yeah, there’s a lot -- 


 MR. GRIFFON: It might be useful to reference 


the older ones as well. You can say it wasn’t 


formal but there were existing practices for 


that. 


 DR. ULSH: Okay. We can do that. 


 MR. GRIFFON: But to demonstrate that it wasn’t 


merely post-1989. 


 DR. ULSH: Sure. As Jim mentioned, the Link 


and Pennock reference from 1983 won’t have the 


level of detail that the later one did but we 


can reference both of them. 


 MR. GRIFFON: Right. 


 DR. ULSH: Sure. 


DR. MAURO: I got a question that links what 


we’re talking about now back to the no data 


available. 


 DR. ULSH: Okay. 


 DR. MAURO: According to the no data available 


there were two times when that would be 


inserting in a person’s record, two conditions. 


One was when the badge was not returned, okay; 


and the other was when you got a problem with 


the dosimeter badge. Now -- But I -- Now, I 


just heard, though, that there were provisions. 

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The badge had multiple elements so that really 


you should not have a circumstance where you 


would get a no data available because of a 


problem with the badge. But when you say a 


problem with the badge that means the entire 


badge? I mean something -- something -- In 


other words, you didn’t just lose an element. 


You -- You -- Something was wrong with all of 


the elements on the entire badge and it was 


just unusable? 


 DR. ULSH: No, that’s not really what I’m 


saying. Jim, do you want to -- 


 MR. LANGSTED: Well, John, you could have 


everything from, you know, one crystal alone 


that was resolved on the spot, to multiple 


crystals that was fairly complex and would have 


to go to the professional dosimetrists to look 


at. And in the dosimetry shop where you were 


trying to turn the results around, you know, 


like on the two-weekly badges, you were trying 


to turn those results around and get them back 


down. Meanwhile the monthlies were sitting 


there ready to read and the quarterlies were, 


too. Sometimes the final report would be run 


even though the dosimetrist hadn’t worked out 

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those details yet. And if it required, for 


instance, going to the supervisor or going to 


the employee to find out what they were doing 


and who else was working with them to do a -- a 


co-worker analysis, so it sometimes was the 


case where it would take awhile to get 


resolved. 


 DR. MAURO: And this was the fault of dealing 


with this aberrant situation where you are 


trying to keep your records? 


 MR. LANGSTED: Right. Yeah, you wanted to get 


the report done and back down to the supervisor 


so he could manage his group. And it was 


frustrating from the employee standpoint 


because they would see no current data 


available; wait a minute, I turned in this 


badge. And so -- and the follow-up was 


definitely not perfect so the employee may 


never have heard what the final result was. 


 DR. MAURO: This is a badge management problem 


as opposed to this other issue where you have 


these elements that just were happening due to 


fallout. 


 MR. LANGSTED: Correct. 


 DR. MAURO: And you had a backup situation to 

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deal with that? 


 MR. LANGSTED: Yeah, yeah. 


 DR. MAURO: So that’s the distinction. 
I 


understand. 


 MR. LANGSTED: But the backup may sometimes 


have taken long enough that, you know, the 


report went, you know. Finally somebody would 


make the decision, go ahead and run the report 


and the -- the five that weren’t in there or 


the one that wasn’t in there went in as no data 


available. 


 DR. MAURO: I understand. Thank you. 


 DR. NETON: I just had a quick question. 


 MR. ELLIOTT: Is it fair to say that a better 


descriptor of this kind of event -- I guess 


I’ve seen at other facilities, INEL one -- is 


result under investigation. I’ve seen that 


entry. Would that be -- have been a better 


descriptor for this kind of occurrence? 


MR. LANGSTED: In some cases, although in many 


cases the situation was that the badge had not 


been exchanged so -- and as we discussed, Rocky 


Flats did not have a tight exchange program. 


And if a worker did not exchange their badge on 


the board --

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 DR. NETON: I just had a quick question. At 


any time did Rocky Flats initiate glow curve 


analysis capability at all so that you could -- 


you could clearly differentiate these -- these 


phosphate detergent bars and chemical burns 


from the TLD’s? 


 MR. LANGSTED: Yeah, when the -- when the 


Panasonic system came in in 1989 you had glow 


curve --


 DR. NETON: And that would clearly be part of 


the --


 MR. LANGSTED: -- investigation. 


 DR. NETON: -- investigation. 


 MR. LANGSTED: Exactly. 


 DR. NETON: And that would -- that’s proof 


positive at that point -- 


 MR. LANGSTED: Right. 


 DR. NETON: -- that this was not a result of a 


radiation luminescence as opposed to a 


chemical. 


 MR. LANGSTED: Right. You would look at the 


glow curve and could see the issue. 


 MR. GRIFFON: All right. That’s essentially it 


then. 


 DR. ULSH: Okay. That’s -- That’s comment 

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number 3 about the contaminants on the chip. 


Whatever designation we’re using to mean that 


NIOSH has turned in a response and, I don't 


know, you, Mark, or someone’s reviewing it. 


 MR. GRIFFON: Yeah, I mean I’m keeping track. 


I’m keeping track of these. 


 DR. ULSH: Okay. 


 MR. GRIFFON: I would say the only outstanding 


action item is that NIOSH will provide other -- 


other historical QC references. 


 DR. ULSH: Oh, are you talking about the Link 


and Pennock reference? 


 MR. GRIFFON: Yeah. 


 DR. ULSH: Okay. 


 MR. GRIFFON: I mean that’s ’83 so it’s -- 


 DR. ULSH: That’s on the O drive, Link and 


Pennock is on the O drive. 


 MR. GRIFFON: Yeah. But also that’s 1983 so if 


there’s anything -- if it goes back further 


that would be more helpful. But other than 


that I would say that response is complete by 


NIOSH. 


 DR. ULSH: So you’re looking for an earlier 


reference than the ’83 Link and Pennock? 


 MS. MUNN: I think he’s asking whether there is 

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one. 


 MR. GRIFFON: As best you can, find proof 


that this practice went -- went back through 


the program. 


 DR. ULSH: We’ll take a look, Mark. 


 MR. GRIFFON: Yeah. 


 DR. ULSH: I’m not aware of any yet but we’ll 


take a look. Okay. Comment number 4. This is 


the assertion that deliberately false entries 


were made into dose records. And the comment 


reads, there’s a deliberate falsification of 


data. For instance a worker alleges that a 


supervisor would advise the dosimeter worker 


that the dose shown was too high to possibly be 


correct, and the worker was advised to change 


or delete the reading. Further in -- further 


on in the petition, the worker alleges that 


zeros were entered into dose records when TLD ­

- when the TLD reader failed. Okay, our 


response to this is that both of the situations 


described in the comment, that is, a worker was 


advised to correct an anomalously high 


dosimeter reading; and the second is that a 


zero was entered into the dose records when a 


TLD reader failed. Those are both plausible 

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situations that very well could have occurred. 


However we contend that that does not 


necessarily constitute deliberate fraud. 


That’s a very serious charge and we’ve 


presented -- you’re going to notice a lot of 


the language here is similar between comment 


responses. That’s deliberate. I did that on 


purpose. There are certainly other 


explanations and those include what we’ve 


talked about; that suspect dosimetry readings 


were investigated and the conclusion of that 


investigation could have been that a lower 


reading was inserted. Now, I would also 


mention that the Rocky Flats dosimetry program 


was similar to the dosimetry program at other 


DOE sites. It was subjected to a number of 


audits and inspections over the years and that 


includes both within the contractor 


organization and outside the contractor 


organization. We are not currently aware of 


any findings of systematic fraud. And this is 


a very serious charge so I would expect that it 


certainly wouldn’t be buried. We have followed 


up. This ties in with the letter that we sent 


to the petitioner on March 15th and that 

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151 

Jennifer said the response is on the way. Once 


we get that letter we will consider it very 


seriously and look at any of the reports to see 


if there’s evidence of systematic fraud. So I 


guess the action item, Mark, should be that 


NIOSH will review the -- 


 MR. GRIFFON: Petitioner’s response. 


 DR. ULSH: Exactly. Okay. The next comment is 


comment number 5 and that is that the petition 


provides examples of unauthorized work 


practices, and it says that the data integrity 


implications of this are unclear. The response 


-- I took a look at the page that was 


referenced here and it deals with what the 


petition called furtive job tasks. In other 


words, jobs that were performed, and this is a 


quote, “outside the bounds of normal work 


controls with no airborne contamination 


monitoring and with no special worker 


monitoring.” This is a situation where I think 


we need to differentiate between a regulatory 


compliance violation and a situation that would 


prevent NIOSH from doing sufficiently accurate 


dose reconstructions. If the furtive -- okay, 


I don’t want to say if. These furtive job 

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tasks, which could certainly represent a 


compliance violation; we’re not contending 


that. But if they were wearing dosimetry we 


could estimate the doses. So I don’t really 


see, if you grant that these situations 


occurred, I don’t see how that necessarily 


constitutes an SEC issue. And no evidence is 


really provided at this point in the petition 


that would say that NIOSH could not estimate 


doses even from these furtive job tasks. 


 MR. GRIFFON: I think that completes -- Other 


opinions? 


 DR. ULSH: I think you’re about to hear one. 


 DR. MAKHIJANI: I think the TLD piece of it 


does address the external dose. 


 MR. GRIFFON: Arjun, can you (unintelligible) 


 DR. ULSH: Maybe that’s not plugged in. 


 DR. MAKHIJANI: The -- The TLD piece of 


Brant’s response does -- does -- does address 


the external dose question in these noncompliant or potentially non-compliant work 


practices. But there’s also the question of 


the internal dose and those special bioassays. 


I don't know what the full radionuclide list 


is. 

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153

 DR. ULSH: Okay. My response to that side of 


it would be very similar. Presumably radiation 


workers were on routine bioassay programs and 


so that would be picked up on -- in routine 


bioassay. In fact, there’s an example later on 


in these comments of exactly that. Whether an 


intake resulted from a furtive job task or from 


a normal job task it should show up in a 


routine bioassay. Now, the problem might be an 


intake might not be immediately recognized as 


having happened. For instance one of these 


furtive job tasks occurred and six months later 


there was a positive bioassay. It is true that 


we may not be able to pin this event on this 


specific incident or a specific job task. 


However, we have procedures in place by 


assuming a chronic intake that we would provide 


a claimant favorable -- claimant favorable 


estimate from that positive bioassay. So I 


think the argument is the same for both sides. 


Assuming that they were monitored that’s an 


integrated measure. 


 DR. MAKHIJANI: This is a clarification since ­

- since I’ve been through the petition and put 


this list together. The -- My purpose in 

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154 

putting the list together was to try to compile 


everything that relates to data integrity and 


leave it to you to characterize what may or may 


not be an SEC issue. I wasn’t -- I didn’t view 


my job as putting an SEC screen through this 


list. I viewed my job as simply putting all 


the data integrity issues on the table as best 


I could see them. It is a 700-page-odd 


petition so this was -- this was not -- I 


can’t, you know -- I did the best I could. 


 DR. ULSH: Okay. So I think that’s our 


response for this comment, that we don’t -- 


NIOSH at least doesn’t see this really as an 


SEC issue. Mark, I don't know where you want 


to put it in terms of the stage of resolution 


that we are with this. 


 MR. GRIFFON: I think you’re complete as far as 


the response, okay? 


 MS. MUNN: Especially --


 MR. GRIFFON: I tend to think you’re correct 


that it doesn’t seem like an SEC issue. 


 MS. MUNN: Especially for this particular 


claimant. Radiation control technicians do in 


fact have specialized training and if anyone is 


sensitive to the need for badging requirements, 

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155 

it should be a radiation control technician. 


 DR. ULSH: Okay. The next comment, comment 


number 6 found on page 8 has to do with 


inappropriate subtraction of background in 


badges. An example is, let’s see. The 


petition claims that there are systematic 


errors for some workers caused by subtracting 


too high of a background. This is an issue 


that we investigated early on and it’s somewhat 


mysterious to us. In order to evaluate this 


issue we initiated a records review and we 


looked at approximately 18 boxes of external 


dosimetry records and those included weekly and 


monthly status reports from the ’50s, ’60s, and 


’70s and some technical documents generated 


during that period. There was about 500 pages. 


We didn’t find any evidence -- I don't know, 


there sure seems to be some interference. I 


don't think it’s coming from me but -- We 


didn’t find any evidence of an elevated 


background problem. And in fact, we talked to 


four retired dosimetry program managers and 


none of them could recall this issue either. 


In worst case what would be required -- 


UNIDENTIFIED: Hello? 

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156

 DR. ULSH: Hello? 


 MS. MUNN: Hello? 


(unintelligible)


 MS. MUNN: Who are you and what are you saying? 


 DR. WADE: There’s a background discussion 


going on that we can hear. 


(unintelligible)


 MS. MUNN: They don’t care. 


 DR. WADE: Okay. We’re picking up a background 

discussion. 

(unintelligible)

 DR. WADE: Okay. Let’s continue. 

 DR. ULSH: Okay. In the worst case, even 

though we’ve not found any evidence of this 


problem, but if -- if it did in fact occur, 


what would be required is that we would adjust 


the ambient environmental dose that we assign 


during dose reconstruction. So we don’t see 


this really as an issue that would preclude us 


from doing sufficiently accurate dose 


reconstruction but I understand, Arjun, that 


you’re just putting everything on the list. So 


NIOSH contends that we wouldn’t classify this 


as an SEC issue. 


 MR. GRIFFON: But is this a question of having 

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157 

the -- the -- the badges, the control badges 


hung in like a hot area or a (unintelligible) 


hot area rather than in a -- in an actual 


controlled area? Is that the issue they’re 


bringing up here? 


 DR. ULSH: You do see at the top of page 8, 


Mark, there are two bullets and it says workers 


in the building who were not in the back area 


were receiving unmonitored dose just like the 


dosimeters on the board. So it could be. 


 MR. GRIFFON: Yeah. Okay. 


 MR. BUCHANAN: Yeah, this is Ron. I think what 


they’re talking about there is the scale 


(unintelligible) if you hang the control 


dosimeter outside the work area and then 


(unintelligible) and then track that off from 


the (unintelligible) corporate badge then 


they’re getting cheated on their dose. 


 MR. GRIFFON: Right. 


 MR. BUCHANAN: But the control badges 


(unintelligible) put in a background area not 


subject to any radiation handling issues 


(unintelligible) 


 MR. GRIFFON: I don’t see -- I don’t see it 


relevant to environmental -- environmental 

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158 

exposure, to ambient exposure. I mean this is 


more of a -- I mean that’s my statement is what 


Ron said, this question of how to control -- 


placed too close to the workplace or too close 


a proximity to the high exposure areas or 


higher exposure areas. 


 DR. ULSH: Right.


 MR. GRIFFON: And therefore you’re tracking out 


more than you should when you’re reading. And 


that’s the allegation I guess. 


 MR. BUCHANAN: (unintelligible) 


 MR. LANGSTED: The research demonstrates that 


the control badges were not hung with the 


boards. The control badges in fact were kept 


in the dosimetry lab and so the fact that that 


the board may have been in a high background 


area would have added additional dose to the 


workers, not subtracted dose via the control 


badge. 


 MR. GRIFFON: Okay. So you’re saying the 


control -- okay. So that (unintelligible) 


MR. LANGSTED: Yeah, that’s what all this 


research that was done looking through the 


boxes and interviewing the -- the managers was 


to try to determine if in fact the control 

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159 

badges were there, and the conclusion was, no, 


they were no. 


 MR. GRIFFON: Okay. 


 DR. ULSH: I could have made that clearer in my 


response. I apologize for that. Okay. 


 MR. GRIFFON: That’s okay. I’m reading as I’m 


listening, too, so it’s kind of -- okay. 


 DR. ULSH: Are we -- Are we ready to move on 


to comment number 7, Mark? 


 MR. GRIFFON: Yeah. 


 DR. ULSH: Okay. That’s found at the bottom of 


page 8. The comment deals with workers 


frequently did not wear badges in production 


area and did not report non-use of the badge. 


The comment says that this raises the question 


of how missed dose is to be interpreted. All 


right. The response is that in a situation 


where such a practice is alleged -- alleged or 


suspected we have methods to adjust the 


recorded dose appropriately. The reference 


that I would provide here is the External Imp. 


Guide where we talk about the nearby technique 


where we can extrapolate from a worker’s 


adjacent monitoring periods. Alternatively we 


could treat that particular badge reading as 

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suspect, not reliable, and essentially consider 


the worker to be unmonitored during that 


period, and we could apply co-worker data, 


whichever is more claimant favorable, to use 


the actual badge reading or to use the coworker approach. Either way I think we’ve got 


a bounding technique here for dose 


reconstruction so I think this might also be a 


situation where NIOSH would contend that this 


does not prevent us from doing sufficiently 


accurate dose reconstructions. 


 MS. THOMPSON: This is Jennifer. Can I 


interject something? 


 DR. ULSH: Sure. 


 MS. THOMPSON: That assumes that you know that 


the worker went in without his badge. That 


assumes the worker remembers every single time 


he ever went in without his badge and reported 


diligently that he did that. And that’s not 


the case. 


 DR. ULSH: That -- That could very well be 


true. I don't know how we would identify 


situations if --


 MS. THOMPSON: It seems many of your answers 


assume that procedures were followed 100 

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161 

percent -- 100 percent of the time. That also 


is not the case. 


 DR. ULSH: No, I certainly wouldn’t -- wouldn’t 


contend that procedures were followed 100 


percent of the time. There are clear examples 


where they weren’t followed. But my contention 


is that they wouldn’t prevent us from doing 


adequate dose reconstructions. Now, in terms 


of how could we identify a situation where this 


might have occurred, we can look at populations 


of data certainly and -- and see where there’s 


a tailing off. So in other words, as workers 


approach the administrative limits in place at 


the time, what you’ll see is that the recorded 


doses sometimes tail off. Now, there could be 


two explanations for that. One is that they 


were approaching the limits and they were -- 


they were restricted from radiation work. The 


other is that their badge didn’t enter the 


radiation area. In other words, they were left 


in the locker which is what the contention is. 


We do have methods to identify situations like 


that and I think we would rely on those 


techniques in addition to situations where this 


was alleged by the worker. In terms of could 

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162 

this ever have occurred and could we detect it 


in all situations, I think the answer has got 


to be no. I don’t -- I don’t think that we 


could. So this might be an issue for the Board 


to decide based on this. 


 MR. GRIFFON: And again it’s a question of -- 


of how frequent the practice was. I mean we --


we have the (unintelligible). But it, you 


know, it’s very difficult, especially when, 


number one, your question here doesn’t ask 


whether anyone didn’t wear a badge, you know. 


And -- But then secondly, it involves 


survivors that are -- that are going through 


this process so they -- you wouldn’t -- you 


would never have that (unintelligible) 


obligation in that case. So, you know, I agree 


that there’s concern here on how this could be 


used or applied. 


 MR. PRESLEY: How many cases do we have in this 


-- in this category? Did you catch that, Mark? 


 MR. GRIFFON: I can hardly hear you, Bob. 


 MR. PRESLEY: My question was how many cases do 


we have in that category. 


 MR. GRIFFON: That’s what I’m saying. I don't 


know that we know. I mean I don't know how, 

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you know -- if that’s what we’re saying, how 


can -- how can you identify the cases? One is 


-- Brant just described the -- the methods but 


it -- it could be that you have real effective 


controls on the one hand. Or any time they 


approached their limit they left their badge in 


the locker is the other possible explanation so 


they could keep working. And, you know, my -- 


my concern is if you just wait on a claimant to 


allege that, they generally say that they don’t 


remember when they did those specific, you 


know, when they did it. And number two, they 


may not be living or -- or, you know, there may 


be a survivor situation. 


 MS. THOMPSON: Mark, another thing is the fact 


that the workers are fairly smart, and if they 


worked in an area where they know it’s high 


rad, they’re not going to wait for the end to 


leave their badge in their locker. They’re 


going to wear it every third day. 


 MR. GRIFFON: Right. 


 MS. THOMPSON: You know these people. They’re 


-- They’re relatively intelligent people. 


 MR. GRIFFON: But do you -- do you -- Jennifer, 


do you know certain departments where they knew 

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that, you know, they didn’t want to get shifted 


out of a certain department because the -- the 


alternative was a worse option for work? 
I 


mean I’ve heard that several times where I’ve 


been that -- that people would do this practice 


because they didn’t want to get shifted to 


another building where it was going to be, you 


know, a much harder job, much hotter 


environment, whatever, you know. A hot -- I 


talking about temperature hot, you know. 


 MS. THOMPSON: Yeah. You actually have several 


factors that come into play. You know, you 


have a hot area, say, and so you’ve got paid 


for to work in the environment in which you 


were known to receive radiation exposure so 


there’s a financial incentive to be able to 


stay in that area. In addition, there is more 


overtime -- historically has been more overtime 


given in areas that have the higher rad work 


and so if you get opted out you can lose a lot 


of money in overtime pay. So people generally 


didn’t want to get transferred to the cold side 


because of financial reasons. 


 MR. GRIFFON: Right. 


 DR. ULSH: One thing I would point out is that 

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 MR. GRIFFON: (unintelligible) hot 


(unintelligible) narrow it down that much. 


 DR. ULSH: One thing that I would point out is 


that after 1964 the TLD or the dosimetry badge 


was incorporated with the security badge so I 


don't know that you would have access to these 


areas if you weren’t wearing your badge. Now, 


before that --


 MR. GRIFFON: Although access to the area, 


would that necessarily mean they wore it right 


to their work stations? 


 MS. THOMPSON: Yeah. Absolutely not. Your --


You only had to have your badge to get in 


through the outer security gates, not into 


like, say unless you’re (unintelligible) access 


area. 


 MS. MUNN: Oh, my. 


 MS. THOMPSON: That was (unintelligible), you 


know, actually where they separated the 


dosimeter badge from the security badge, it was 


security became more strict. And so having 


them together in the later years your statement 


would be correct. 


 DR. ULSH: Okay. I don't think that at the end 

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of the day NIOSH is going to be able to say 


with any certainty that when workers 


deliberately suppressed the readings on the 


dosimetry badge that we would have a method to 


correct that -- to catch that in every case. 


think that’s -- you can always come up with a 


hypothesis, a scenario where we wouldn’t catch 


it. So --


 MS. MUNN: Especially if --


 MR. GRIFFON: I mean I’m not trying to -- 


 MS. MUNN: -- the workers were complicit. 


 MR. GRIFFON: -- the frequency with which that 


practice occurred. 


DR. NETON: Deliberate workers (unintelligible) 


 MS. MUNN: No. When the worker is complicit 


in the use then --


 DR. ULSH: So at the end of the day that’s 


where that leaves us. And I think the Board 


has to decide whether they want to consider 


this situation to be an SEC issue. I don't 


know that, Mark, that we’re going to be able to 


get a handle on how often this was done, given 


the workers’ reluctance to talk about it or 


even maybe their inability to remember when it 


happened. We do have methods in place to catch 


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it in I contend a great number of cases. Can I 


tell you that we could catch it all the time? 


No. I can’t say that. 


 MR. FITZGERALD: Could I -- Could I just --


 MR. GRIFFON: Jennifer? Jennifer, do you know 


of -- of individuals that are in the petitioner 


group that have -- that have more specific 


examples of when, where? I know that’s 


difficult. 


 MS. THOMPSON: You know, and I apologize for -- 


for not remembering but there is a woman from 


(unintelligible) and Associates that’s in town 


in Denver right now and I believe she’s talking 


to some of the -- the workers about types of 


issues. And she may be gaining testimony or 


information that would further elaborate on 


this right now. I know she’s been meeting with 


several people in the last couple days. 


 MR. FITZGERALD: Yeah, Mark. This is Joe. 


 MR. GRIFFON: (unintelligible) 


 MR. FITZGERALD: Yeah, just -- just to clarify 


for those around the table that don’t 


understand what’s going on. We have Kathy 


Robertson-Demers pursuing the issue we raised 


in Boston which is trying to find some 

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substantiation beyond the anecdotes and the 


allegations, just see if there’s anything more 


concrete that might shed some light on this. 


And that’s what she’s doing this week in Denver 


which is talking to workers, see if there’s any 


corroborating information that we haven’t seen 


so far and to try to add that to the 


discussions and we’ll see what we get. We 


haven’t talked to her yet. 


 MR. GRIFFON: Brant, I think that where I’ll 


leave this is that, you know, NIOSH has 


completed the action but we’ll leave the item 


open as opposed to -- I think several of the 


other ones we sort of projected that they’re 


not SEC. I think this might be 


(unintelligible) here pending some of, you 


know, further specific information if it’s 


available. 


 DR. ULSH: Yeah, I think that’s probably 


appropriate and I think we’ve provided as much 


as we really will be able to. 


 MR. GRIFFON: Right. 


 DR. MAKHIJANI: Mark, could I make a correction 


for the record? This is a minor item compared 


to -- It says here, the citation in the 

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I 

comment appears to be in error. I don’t think 


it is in error. I’ve got the petition open. 


just -- it’s not a quotation from the petition. 


It was a paraphrase. The petition words are 


(reading) workers also frequently forgot to 


wear their dosimeters into the production areas 


and most would not self-report so doses went 


unreported. So it -- it was something of a 


paraphrase but --


 DR. ULSH: Okay. I think it caught the spirit 


of it. I’ll take it back. 


 DR. MAURO: This is John Mauro, Brant. You had 


mentioned, though, that you do have a way to 


not catch them all but to identify occasions 


where either it was inadvertent or deliberate 


where the badge did not go with the person. 


Now, what I’m hearing, this is a recurring 


issue. That is, on many occasions we encounter 


allegations that -- of deliberately not 


bringing the badge with you for -- for 


financial reasons that had implications. Now ­

- But I heard you say something very 


important, that by reviewing the records there 


are times when you could discern that there -- 


there’s something about the pattern of 

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exposures that would lead you to believe that 


here we might have a -- a reporting period 


where the badge did not go with the person. Am 


I correct that -- that -- that you have a way 


to -- now, it seems to me that without making a 


judgment regarding whether it was deliberate or 


inadvertent, if a sample of records were to be 


reviewed and you were to use the methodology 


you described, we could start to get a sense of 


the prevalence of this type of pattern. And 


because to me the big -- the bigger question is 


is it -- is this a widespread issue or not. 


And I guess to the extent to which there’s some 


metric that could somehow reveal how widespread 


this is or -- or not, it would be very helpful 


to not only address the issue as we’re 


encountering it here but as we have encountered 


it at other -- other petitions and site 


profiles. Is this something that’s doable, 


reasonable? 


DR. NETON: I’ll take -- I’ll take a crack at 


that. I think it is something that is doable. 


How soon it could be done is another question. 


I mean, you know, these -- these type of 


analyses take time. We’d have to pull up the 

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data. I guess, you know, we could -- we could 


take a quick look at the -- this would only 


affect workers with fairly significant 


exposures. 


 DR. MAURO: Uh-huh. 


 DR. NETON: And our evaluation of records, 


particularly in the more recent years, there’s 


very few workers that approach the limits. 


Now, maybe in the very early years when doses 


were not as well controlled we might have more 


issues like that but we could look at the tail-


off of the cumulative dose on a worker by 


worker basis to see how many -- how many 


workers that may have affected. In other 


words, as -- as the worker approaches the limit 


does his exposure tail off dramatically at the 


end which would indicate that the badges were 


left in the lockers or whatever. 


 DR. ULSH: Or that they were pulled out. 


 DR. NETON: Or that they were pulled out. It 


could be either situation but it would give you 


a handle on the extent of the potential problem 


as you suggested. 


 DR. MAURO: That’s what I’m looking for, the 


extent. 

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 DR. NETON: We could take a look at that but I 


couldn’t promise that this would be done in -- 


in a couple weeks. That’s -- That’s the -- as 


far as I can comment. 


 MR. GRIFFON: I think can you give us a -- I'm 


not sure how to leave that. I think that would 


be useful, Jim, but --


 DR. NETON: Well, I guess -- 


 MR. GRIFFON: Again the extent of -- of how 


much work has to be done. 


 DR. NETON: Well, I think that, you know, if -- 


if we leave this as an open item and -- and we 


-- we list it as one of the potential avenues 


to pursue we could come back with a better -- 


 MR. GRIFFON: Give an update on what you find, 


yeah. 


 DR. NETON: Yeah, after looking -- looking at 


it. And -- And, you know, I’m guessing that 


it would be possible but oftentimes I’m a 


pretty bad prognosticator. 


 DR. WADE: And again we’re going to move into 


an SEC phase so NIOSH could consider whether to 


produce such evidence and provide it in the 


evaluation report or bring it to its 


presentation at the April meeting. 

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 DR. ULSH: I can almost guarantee that we will 


not be able to get it into the evaluation 


report because that’s due to come out within 


the next week or -- week or so. 


 DR. WADE: So again you can consider whether or 


not you want to bring such evidence to the -- 


to -- to inform the discussion at the end of 


April. 


 DR. NETON: Right. It sounds like SC&A is 


pursuing this issue from a different attack 


with the interviews of workers and so it seems 


like this will be fleshed out in -- in greater 


detail in the near term. 


 MR. GRIFFON: Yeah. 


 DR. NETON: And we’ll -- I think we should just 


leave this one path open and look at the 


tailing as a possibility, as one of the 


alternatives and if we can fit it in, we will. 


But if we can’t maybe the weight of the 


evidence on the other issues will -- will help. 


 MR. FITZGERALD: Just to -- Just to add a 


little bit to what we’re doing this week, it’s 


really to get a handle on what John was talking 


about. Whether or not we could provide any 


substantiation this is systemic and pervasive, 

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not to get more, you know, individual 


testimonies or affidavits or data items. 


That’s not going to, I think, move us forward. 


It’s to really determine if there’s some 


evidence that this -- this pervades perhaps the 


operational history and see if there’s any 


documentation to support that. 


 DR. NETON: And of course, this would not be 


informative at all for the workers who -- who 


assert that they just forgot to wear their 


badges. That -- That would be independent of 


the cumulative dose. I would suspect so unless 


they forgot is a euphemism for didn’t wear it 


because they were approaching the limit. 


 MR. GRIFFON: Jim, would this database data, 


does it have every badge cycle on it or is it ­

-


 DR. NETON: Yeah, that’s a good question. I 


think with Rocky we’ve got situations where we 


only have --


UNIDENTIFIED: Quarterly. 


 DR. NETON: -- quarter -- quarterly data? 


UNIDENTIFIED: Yeah. 


 DR. NETON: Yeah. See, we’ve -- we’ve 


attempted to investigate this at the Hanford 

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facility where we had weekly data. It’s --


It’s a -- It, you know, provides for a better 


analysis so again that’s why I’m -- I’m 


reluctant to say that we can do it for Rocky. 


We need to take a look and see what -- what can 


and can’t be done. 


 MR. GRIFFON: Right. 


DR. NETON: Right. You know, it may be that it 


can’t be done. 


 DR. WADE: And this sort of raises a generic 


process issue -- this is Lew Wade -- that I’d 


like to talk about a little bit. Again, the 


Board is going to be sitting with the petition 


evaluation report in front of it at the end of 


April and there will be a great deal of 


pressure on the Board to make a decision at 


that point. It doesn’t mean the Board has to 


make a decision but there’ll be a great deal of 


pressure. So I think that all of you involved 


in this process, as you uncover information, I 


think it would be incumbent on you to share it 


with the Board as quickly as possible, not to 


wait until that April meeting so that the Board 


can have the opportunity of sort of mulling 


through these things, each individual Board 

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member in their own way as they come to the 


Denver meeting and decide upon this issue. So 


again, if we find things from the Demers 


interviews then we need to be providing them to 


the Board as quickly as reasonable. 


 DR. ULSH: Okay. Unless anything -- 


 MR. GRIFFON: We’re on to item 8 then. 


 DR. ULSH: Yes, okay, item 8, good. This 


comment raises three issues as I count them. 


The first has to do with geometry. Would a 


badge accurately -- could a badge result 


accurately be used to calculate doses for 


readings that weren’t close to the badge. 


That’s issue number one. Issue number two is 


lead aprons and what effect that might have. 


And issue number three is what effect might all 


this have on co-worker data. So let me just 


walk through those. First of all, it’s not 


clear to us how a badge could not be used to 


calculate doses to organs far from the badge. 


And an example of NIOSH’s approach for -- for 


doing this is our glovebox worker TIB where we 


have badge results in for organs in the lower 


abdominal -- lower abdominal area. We make an 


adjustment based on geometry. So we agree that 

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this issue needs to be considered and an 


adjustment needs to be made; we contend that we 


can do that and we are doing that. With 


respect to lead aprons, there’s a question 


about were the badges were worn under the lead 


aprons or over the lead aprons, and that -- 


that changed throughout time at Rocky Flats, 


the instructions on that. Lead aprons were 


available for -- for limited use at Rocky Flats 


and for most years they were instructed to wear 


the badges under the lead apron. And in 1992 


that was changed to instruct the workers to 


wear the dosimeters outside the lead apron. 


Now, the issue here is if I’m wearing my badge 


underneath my lead apron and I get a cancer in 


an exposed part of my body, say for instance 


the esophagus, how can we estimate doses for 


those organs that weren’t covered by the lead 


apron? Well, as it turns out there were field 


studies performed to determine dosimeter 


responses in both locations of the film badge, 


under the lead apron and over the lead apron. 


And I recall the details for -- for Pantex. 


-- Jim, you maybe can correct me about Rocky 


Flats but I think that if you’re wearing the 


I 
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badge under the lead apron the -- the recorded 


dose was just reduced by a factor of somewhere 


in the area of 20/30 percent. 


 MR. LANGSTED: I don't recall what that number 


was right off but yeah, there was a measurement 


done specifically for that. 


 DR. ULSH: So I -- I would put this into the 


category -- I really like John’s term of a 


tractable issue. An adjustment does need to be 


made and it can be done. It’s not -- It’s not 


one of these issues where we can’t estimate the 


effect of -- of lead aprons. Now, I think 


Arjun wants to (unintelligible) 


 DR. MAKHIJANI: Brant, would that -- would that 


not cut off the shallow dose altogether? 


 DR. ULSH: Yes, it seems like it would. So 


where do you go from there? 


 DR. MAURO: So to make it tractable you’d have 


to have some knowledge on the -- the energy 


spectrum to which the shielded badge is being 


exposed to? Then -- Then -- Then we have a 


tractable issue. I guess that’s what -- and -- 


and is it reasonable to assume that you would 


have that information? 


 MR. LANGSTED: Yeah, we should be able to get 

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skin to penetrating dose ratios from co-workers 


to look at --


 DR. MAURO: Okay. 


 MR. LANGSTED: -- in a case like that. You 


know, this would -- you know, if there were 


like Brant said a lead apron issue with a 


cancer outside, that would take some special 


dose reconstruction outside of the normal 


process. 


 DR. ULSH: Now, the -- the other issue, the 


question that was raised in the comment -- 


would you want to chip in? I think that -- was 


that Mark? 


 MR. GRIFFON: Nope, I didn’t have anything. 


 DR. ULSH: Okay. The other question that was 


raised in the comment is how would this impact 


on co-worker data. And I think if you give 


some thought to how we do co-worker data I 


think the conclusion you can come to is that it 


wouldn’t affect it because what we do when we 


assign co-worker data, we use co-worker data to 


get whole body doses to assign to an 


unmonitored individual. Once that assignment 


has been made for a whole body dose we then go 


on and apply dose -- dose conversion factor, 

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organ specific dose conversion factors. So I 


don't think that this would have implications 


for the co-worker data. 


 DR. MAKHIJANI: If -- If the lead apron 


problem was there for most of the time or much 


of the time, then how do you estimate the coworker doses for -- for the shallow dose? 


Because the whole body dose is not going to 


give you that number unless you have an 


explicit study for the inside the apron and 


outside the apron when the shallow dose 


recorded and comparable radionuclide situations 


like, you know, the americium percentages 


controlled and so on. You wouldn’t know what 


to do. 


 DR. ULSH: Keep in mind that lead aprons were 


used on a very limited basis so when we’re 


talking about co-worker data, the impact that 


that might have on the entire data set I think 


would be pretty small. And as Jim mentioned 


earlier we could use co-worker data to get the 


ratios of penetrating to shallow dose and apply 


those to the individual. I think, Jim, do you 


want to --


 DR. NETON: Well, I -- I just have a question 

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really to Jim’s comment that your recollection 


was that the difference was on the order of 


only 30 percent? 


(unintelligible)


 UNIDENTIFIED: I don't recall. 


 DR. NETON: It seems to me that if Rocky were 


wearing lead aprons it was mostly in response 


to protection to (unintelligible) of photons, 


things like plutonium. And I would suspect 


that a lead apron would have a much larger 


correction factor than -- than about 30 


percent. So I think the answer is we would 


know what the correction factor would be and -- 


and the low energy dose, the shallow dose would 


be relevant to the 17 keV (unintelligible) 


which would be applied. So I think we have a 


handle on that unless you’ve got a unique 


situation where there are pure beta particles 


which, you know, I’m not sure there are that 


many at Rocky Flats. I think that the issue 


can be dealt with with these geometric 


correction factors for apron usage. I would 


have to look at the study but I would suspect 


that they -- they evaluated it, you know, 17 


keV exposure with and without the lead aprons. 

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So we -- we need to take a look at that and 


maybe get that report back on -- on how that 


would be dealt with. 


MS. THOMPSON: This is Jennifer. I’d like to 


provide clarification. Somebody said that lead 


aprons were used on a very narrow basis at 


Rocky Flats and I know that -- that site 


profile didn’t include analysis of more recent 


operations at the site. But many of the rescue 


processing operations where we were doing the 


repackaging on 106 metric tons of residue at 


Rocky Flats involved the use of lead aprons. 


And so, you know, that needs to be reflected in 


-- in whatever -- whatever you think you can do 


to adjust for that. 


 DR. NETON: Jennifer, what time period was 


that? 


MS. THOMPSON: 1995 to the end of probably 


2003. 


 DR. NETON: Right. I think the response 


indicated that the lead aprons -- or the badge 


was worn outside the lead apron after 1990­

something. 


MS. THOMPSON: But the response was that the 


procedure required it to be worn outside but 

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many people still wore it under because they 


had always done it that way. And just because 


a procedure was changed doesn’t mean actual 


practice changed. 


 DR. NETON: Okay. 


 MR. BUCHANAN: This is Ron. At the Pantex 


plant for ’95 (unintelligible) had an overall 


reduction in photon dose of 57 percent and the 


neutrons I want to say (unintelligible) 


percent. And so the neutron dose 


(unintelligible) of course but (unintelligible) 


 MR. DEMAIORI: This is Tony DeMaiori with the 


Steel Workers. I have Jerry Harden with me. 


And I apologize to you. We were working with 


Kathy Demers going through our records. I’d 


like Jerry to speak on what I brought up in the 


last Board meeting about people not wearing 


their dosimeters and the people putting their 


dosimeters on -- on high dose material to 


verify the -- well, basically the dosimetry 


program. So I’m going to turn this over to 


Jerry right now. Thank you very much. Jerry? 


 MR. HARDEN: What is it that you want to know 


from me? 


 MR. GRIFFON: Well, we’re going back in action 

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items that we already discussed I think but the 


-- the question was -- that has come up in the 


petition, we referred that at least some 


workers have alleged they might have left their 


badge outside of areas and worked in hot areas 


for -- or as Tony just said, might have even 


put their badge in a hot drum of some sort to ­

- to sort of test the program to see if they 


were actually measuring doses. We were looking 


for specific examples of where that might have 


happened or how frequently. 


 MR. HARDEN: I don't know about the frequency. 


I know one specific case that occurred in the 


late ’60s. A deceased worker named O.G. Fergus 


(ph). And let me explain the motive why a lot 


of people would attempt to do what we’re 


talking about today. It was about the money, 


honey, or they might lose their shift or their 


various other motivators. And with Fergus, he 


was rotated out 774 building, which was a 


parking lot for -- for high dose workers and 


moved into 71 building. So he assumed if he 


put his badge on a -- a can of oxide that that 


would load his badge and consequently elevate 


his numbers where he would be reassigned back 

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where he wanted to be. And I can’t name all 


the people that I suspect might have been 


involved in either, you know, skewing the data, 


you know, less that it ought to be or more, but 


I -- I do know that case to be a valid one. 


 MR. GRIFFON: And in that case he wanted to go 


back into the --


 MR. HARDEN: From 71 building production back 


into the 74 building. 


 MR. GRIFFON: But he was trying to back out 


of... Well, thank you. 


 MR. HARDEN: And that’s all? 


 MR. GRIFFON: Well, that’s the main thing I 


needed. If there’s any other specifics you can 


give and -- and more so you mentioned the money 


incentive. 


 MR. HARDEN: Well, it wasn’t just that. You 


had the possibility of pregnant females. You 


had all kinds of things and people would lose 


their good deal kind of things potentially, you 


know, in the -- Most everyone tries to work 


themselves, you know, into a comfortable place 


on the porch. That’s what this boils down to 


because people were very sensitive on goals. 


And you had like with production welders where 

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they were eyeball to eyeball with the -- you 


know, our product, you had to do a lot of 


folks. And they did finally rotate it to 


another building. And again I don’t want to 


put names on tables because I don’t have hard 


evidence, but the Fergus case I think is 


relatively solid or was during my last 


awareness. So it isn’t like, you know, this is 


just fantasy. Keep in mind that I was a grunt, 


radiation grunt at Rocky Flats. I wasn’t up in 


the -- you know, in the palace so I’m sure that 


the people in some of those departments have to 


know way more of these specifics than I do. 


 MR. GRIFFON: Okay. Well, thank you. That’s 


what we -- when we say specifics we -- we don’t 


necessarily mean names. 


 MR. HARDEN: Yeah, you do because it looks to 


me like we’re chasing a lot of 


(unintelligible). I’m not just blowing smoke 


in any part of your anatomy. I’m -- I’m out 


here with the real deal. And my interest is of 


a concerned worker of 37 years duration at 


Rocky Flats and I’ve made a long list of people 


that never lived long enough to get their first 


pension check. So I am very emotional and very 

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aggressive about trying to get something done. 


 MR. GRIFFON: Well, we --


 MR. HARDEN: Hopefully you share that. Maybe 


you don’t and I guess we’ll be at odds 


somewhere down the road. 


 MR. GRIFFON: No, we do share that. We 


appreciate your comments. All I was going to 


say is if you have more specifics it might be 


useful to give them to Tony and maybe not bring 


names up on the open line on the call but we -- 


we do want -- the more specific we can have the 


better we can track it back. 


 MR. HARDEN: And -- Now, who are you, sir? 


You know who I am. 


 MR. GRIFFON: My name is Mark Griffon and I’m ­

- I’m with the Advisory Board. I’m chairing 


this work group. 


 MR. HARDEN: I see. 


 MR. GRIFFON: And then there’s a bunch of folks 


in Cincinnati from NIOSH and from SC&A and from 


ORAU, the contractors that are working on this 


project. 


 MR. HARDEN: Okay. 


 MR. GRIFFON: There’s a whole lot of people on 


this phone call. The Advisory Board is 

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chairing this particular meeting. 


 MR. HARDEN: Well, all I can do is tell you to 


do more and do it quickly. 


 MR. GRIFFON: All right. Well, we appreciate 

that. 

 MR. HARDEN: All right. 

 MR. GRIFFON: We are trying. 

 MR. HARDEN: Do you want to talk to these 

people? Tony has no further comment for you 


today. 


 MR. GRIFFON: All right. All right, thank you. 


 MR. HARDEN: Yes. 


 MR. GRIFFON: Well, we’ll get back to -- Brant, 


where were we? On 8? 


 DR. ULSH: I think we’ve gone through item 8, 


Mark. 


 MR. GRIFFON: Yeah. 


 MS. MUNN: (unintelligible) 


 MR. GRIFFON: I think one item there to follow 


up -- you had mentioned that -- follow up on -- 


on something about how you were going to go 


about (unintelligible) 


DR. NETON: Well, we’re going to value -- is 


that the one we were going to look at the 


tailing off of the cumulative dose? 

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 DR. ULSH: No, that was (unintelligible) 


 DR. NETON: We’re moving on to the -- the lead 


apron? 


 MR. GRIFFON: Yeah. 


 DR. NETON: Yeah, we need to take a look -- a 


closer look at that report that was done -- the 


evaluation that was done with lead apron usage 


and the reduction in dosimetry. 


 MR. GRIFFON: Okay. I think we’re on 9. 


 DR. ULSH: Okay. Item 9 deals with an 


affidavit from the petition under the heading ­

- under the heading of missing dose record in 


areas of high exposure. One worker has 


provided an affidavit saying that a year’s dose 


record is missing from a time that he worked in 


a high radiation area. He was a rad control 


technician and he gave the specific location, 


and he says that he was not rotated out of the 


area since he was a rad control tech. This 


goes back to an unmonitored radiation worker. 


If this occurred then we would use the 


techniques that I’ve mentioned earlier where we 


would interpolate from adjacent monitoring 


periods if the job was the same. Or 


alternatively we could conduct a co-worker dose 

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reconstruction. 


 MR. GRIFFON: This was actually -- this was 


being implemented (unintelligible) earlier. 


 DR. ULSH: Yeah, it sounded familiar, Mark, but 


I couldn’t pin it down so I knew it was in 


there somewhere. 


 MR. GRIFFON: It might be (unintelligible) 


 DR. ULSH: I think it --


 MR. GRIFFON: If it was a claimant his files 


are available. 


 DR. ULSH: I think I checked on this and this 


guy’s not a claimant so I don't know that we 


would have access to his records but the 


response is that we do have methods to handle 


situations like this. I mean he would be an 


unmonitored worker essentially for this period 


and so I think we would apply co-worker models 


or use the nearby technique as laid out in the 


External Imp. Guide. 


 MR. GRIFFON: I wonder if -- if this person is 


in the (unintelligible) they may have access to 


their own personnel file. 


 MR. LANGSTED: It would have been requested. 


 MR. GRIFFON: (unintelligible) 


 DR. ULSH: Jim Langsted says that they probably 

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would if they requested it from DOE. Yeah, it 


might -- it might not be able to be done in a 


timely manner. I -- I --


 MR. GRIFFON: And your -- your -- NIOSH’s 


program doesn’t (unintelligible) other 


individual records as part of the overall 


model? 


 DR. ULSH: We certainly have access to de-


identified data but I don't know about chasing 


the individual data for other people that 


aren’t claimants. 


 DR. NETON: I think we need to check into that 


because it’s my opinion that we’ve got usage. 


MR. ELLIOTT: (Unintelligible) takes us beyond 


the claimant’s file, ask for data by co-worker 


data and build a data set. 


 MR. GRIFFON: I didn’t hear that. 


 DR. NETON: That was Larry Elliott -- 


 MR. GRIFFON: Oh. 


 DR. NETON: -- speaking but, you know, we have 


a MOU with DOE that I believe will allow us to 


go beyond just the broad data that we’re 


requesting for the workers and that is to 


obtain additional data for example to develop 


co-worker models. So it’s not clear to me that 

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we couldn’t get this. I’m not saying we can 


but we’d have to check with our legal folks and 


others and make sure that it’s -- it’s 


appropriate but I think it’s something that 


would be worth pursuing. 


 MS. MUNN: The question --


 MR. GRIFFON: The only reason I’m raising it is 


because it’s a very specific one and might be 


very useful. 


 DR. NETON: I agree with you, Mark. I think if 


we could -- if we could investigate this 


specific case -- again and make sure it’s 


possible but if it were I think it would be 


worth looking at. I might say even if we can 


though, we might not be able to get these -- 


these records in a timely manner. 


 MR. GRIFFON: Right. 


 DR. NETON: It might take more than a week or 


two even -- even if we have the authority to 


request that. 


 MR. GRIFFON: Okay. 


 MS. MUNN: It’s unclear to me, however, if this 


person is not a claimant how this affects the 


SEC. 


 MR. GRIFFON: Well, it’s the -- it goes back to 

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the overall allegation, the no data available 


with regard to the database that did use the 


co-worker model. 


 MS. MUNN: So we’re extrapolating the 


allegation to include more than this worker? 


Is that what I’m hearing? 


 MR. GRIFFON: My understanding that was a 


broader allegation as to the specific affidavit 


-- affidavit provided in -- as part of the 


petition. But the allegation was broader. 


They didn’t just say one person said they had a 


record where there was no data available; they 


made a broader allegation. This was one 


affidavit that was very specific to that -- to 


that issue. 


 MS. MUNN: I guess I’d have to go back to the 


CD and look at the (unintelligible) 


 MR. GRIFFON: And that was my understanding. 


If the others -- if the others remember this 


differently I’m --


 DR. MAKHIJANI: Yeah, Mark. This is Arjun. 


Ms. Munn, that is -- Mark is right. The 


petition is fairly complex but part A of the 


petition in certain portions raises many of 


these issues. And then I think these 

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affidavits in part B are kind of collectively 


individual examples demonstrating that the 


allegations are real although, you know, the 


specifics and generalities mixed in both parts. 


 MS. MUNN: Yeah, I’ll go back and look at it. 


It just seems unusual to have a non-claimant -- 


I’ll go back and look at it again. 


 DR. ULSH: Okay. Number 10. This comment 


deals with the bioassays were redone when they 


indicated high exposure. There are two 


examples that are cited. They claim that 


bioassays were redone for individuals and that 


they were recounted when the readings were 


high, and subsequent results were declared as 


having no exposure or false positives. This --


One of these examples is cited as important to 


the basis for the petition. So I’d like to 


walk through these examples. The first one is 


found in part A, page 47 of the petition. It 


gives several details. According to the 


petition the urine samples were positive for 


plutonium, were collected in July of 2003 and 


also later that year in September and December 


of 2003. And it states that there were also 


earlier positives in 2001 and ’02. And it 

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states in here than an investigation was done 


by internal dosimetry including follow-up 


samples that were below the decision level and 


concluded that the 2001 and ’02 samples were 


false positives. In our response we have cited 


a -- the Rocky Flats procedures that govern 


investigation of positive bioassay results, and 


that procedure states that an intake is 


considered confirmed if one of the follow-up -- 


if one of the follow-up samples shows 


detectible levels of activity not associated 


with background or previous intake following a 


workplace indicator which exceeds the action 


levels. So that is pretty much exactly the 


situation that’s described in the example. 


However, I would point out that the example 


does not present any evidence that the 


conclusion that these were false positives was 


in error. The petition goes on to contend that 


the likely explanation is that it says, “it is 


probable that the detection of plutonium 239 


and 240 at this time is the result of improved 


sensitivity in laboratory analysis and that 


there were small amounts of plutonium in the 


urine from old intakes that were only recently 

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detectible.” I agree that’s a plausible 


explanation and that actually supports NIOSH’s 


dose reconstruction methods in that when a 


bioassay result comes back negative we apply 


missed dose so for those early time periods it 


could very well be the case that there was 


small amounts of plutonium present. It showed 


up as a below the limit of detection and we 


applied missed dose. And it’s exactly for that 


reason that if you were to use more 


contemporary, more sensitive methods perhaps 


there would be a detectible level there. And 


that’s exactly the justification for assigning 


internal missed dose. So I don’t see that that 


presents a basis for concluding that we 


couldn’t do accurate -- sufficiently accurate 


dose reconstructions. Now, the second example 


also gives a number of details here. That 


there was an incident which resulted in the 


contamination of a worker. The worker was 


apparently wearing a respirator at the time. 


The petition says that a lung count was taken 


and -- and was positive and a second lung count 


was taken and it was concluded that the first 


lung count was a false positive. And then the 

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worker states that eight years later he was 


given a dose for this incident and he states 


that he gave three fecal samples a number of 


years later, all of which gave positive 


results; and to his knowledge he had not been 


involved in other incidents. Again I would say 


that no evidence is provided that the 


conclusion that the first lung count was 


positive -- was a false positive, that that was 


in error. And I would say that this is exactly 


the justification for routine bioassay programs 


because workers may not be aware that they have 


had an intake unless -- at the time it occurs. 


And that’s the reason that they do routine 


bioassay programs is to detect situations 


exactly like that. So I don’t think -- in the 


absence of evidence that the conclusions of 


false positives were in error I don’t see that 


these examples support the conclusion that we 


can’t do sufficiently accurate dose 


reconstructions. That’s the end. That’s my 


response, Mark. 


 MR. GRIFFON: Yeah, I don’t think your -- I 


mean I don’t think (unintelligible) further 


action --

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 DR. ULSH: Okay. 


 MR. GRIFFON: On NIOSH’s part. Now, it seems 


like the model -- the approaches that are being 


proposed would adequately address the situation 


but I mean I’m not going to (unintelligible) 


reading while you’re talking. 


 DR. ULSH: Okay. 


 MR. GRIFFON: That’s my general sense. I don't 


know if SC&A has any comments on that. 


 DR. MAURO: No. 


 DR. ULSH: I don't think so. 


 MR. GRIFFON: Well, we can leave it that the 


NIOSH action is completed at this point you 


know, no further action. 


 DR. MAURO: I'm sorry. This is John Mauro. 


You had mentioned that there was no evidence 


that the circumstance that was being alleged 


occurred. And namely that -- that the false 


positive was in fact not a false positive. How 


would you I guess -- I’m just trying to think 


of what would be in the record that would 


individual that -- is it the follow-up or is 


the follow-up -- let me see. Let me just think 


it through. So a person has a -- a chest count 


or a bioassay. Get a high result. Automa--

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One of the things that’s done as part of your 


procedure is to follow up, and when the follow-


up is done you go -- you don’t see it again. 


And -- And that is your evidence that in fact 


the original one was a false positive so that’s 


where it ends. 


 DR. ULSH: You’re essentially correct. It’s 


actually stated in the opposite case, that the 


intake is confirmed if one of the follow-up 


samples shows up positive but you could -- you 


do have the right interpretation there I think. 


Okay. Then that takes us to comment -- 


 MR. GRIFFON: I think the -- the most important 


part of that whole thing, you said it, Brant, 


to me, that you’re -- when your zero or unless 


it’s detectable (unintelligible) approach, 


right? 


 DR. ULSH: Right. 


 MR. GRIFFON: So we’re going to be 


(unintelligible) anyway so I think that’s an 


important part of the statement. 


 DR. ULSH: Unless there’s further discussion on 


that we can go to comment number 11. 


 MR. GRIFFON: Okay. 


 DR. ULSH: Okay. And that’s under the heading 

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of instances of no data available in situations 


of high exposure. We’ve talked about this 


somewhat already, this no data available issue. 


 MR. GRIFFON: Right. 


 DR. ULSH: The comment says that there is, for 


instance, an affidavit stating that no data 


available was entered into their record despite 


the fact that the film badge was blackened with 


exposure and the work was in a high exposure 


area, americium 241 processing. And by 


contrast the petitioner -- the affidavit in the 


petition contends that there were entries for 


positive dose when the worker was serving in 


the military in Korea which would certainly be 


troubling. I think we’ve talked about the no 


data available --


 MR. GRIFFON: Is this another individual? I 


think he --


 DR. MAKHIJANI: Mark, I think it’s the same 


one. 


 MR. GRIFFON: Is it? 


 DR. ULSH: Well, let’s take a look over on page 


13. There’s actually a copy of the affidavit 


that I redacted from the petition and if you 


look in the first paragraph of his affidavit he 

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says that when they did my dose reconstruction 


for the neutrons they included May 1963 to May 


1965. I was on active duty in Korea and had 


handled no radioactive material while I was 


away from Rocky Flats. So and then the no data 


available issue is brought up a few paragraphs 


down. But I want to focus on the Korea 


situation here. If you look at the next page, 


page 14 in the handout, what you’ll see here is 


the employee record card for this individual 


and if you look about halfway down in the third 


column, the column that’s titled released, 


you’ll see a date for 4/19/63, so April 19th , 


1963. And the card does show that he quit with 


notice. He was entering the military service. 


So he worked for part of the year, the first 


part of the year in 1963 and then he entered 


the military. A couple lines down you’ll see 


an entry under the hired column, 5/17/65 he was 


rehired. So this does agree with his affidavit 


that he worked a partial year in ’63, was not 


there in ’64 and worked a partial year in ’65. 


Now, in his affidavit he also contended that he 


received neutron dose for this period. Page 15 


of the handout is a copy of the NDRP data sheet 

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for this individual and what you’ll see is that 


there is a dose in 1963 assigned. There is a 


dose in 1965; and there’s no dose in 1964. 


This is entirely consistent with partial year 


employment in ’63 and ’65 and no employment in 


’64. So I would contend that this is not an 


SEC issue. 


 MR. GRIFFON: It also shows let me add an 


annual dose that you mentioned, not both -- not 


broken down further, right? But it does 


support -- It does support -- I mean that’s 


certainly a possibility (unintelligible) 


 DR. ULSH: Okay. So unless there’s further 


discussion on that one I’d move on to comment 


12. Can we consider that one closed? 


 MR. GRIFFON: This person’s obviously an 


individual that’s a claimant, correct? 


 DR. ULSH: Pardon me? 


 MR. GRIFFON: This -- This is a claimant? 


 DR. ULSH: No, in fact this is not a claimant. 


 MR. GRIFFON: Then (unintelligible) the 


records. 


 DR. ULSH: I have the NDRP sheet. But I don't 


have any other --


 MR. GRIFFON: You have his service records and 

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all that. 


 DR. ULSH: Yeah, that was included as part of ­

- was this from the NDRP, Roger? 


 MR. FALK: Yes. 


 DR. ULSH: Okay. This -- This was from the 


NDRP. But I don't have, you know, the typical 


records that we have for a claimant, you know, 


the extensive dosimetry records or anything 


like that. 


 MR. GRIFFON: I was just curious. You seemed 


to get the records. Okay. I would add the 


same action to this one. If possible can you 


track this person back and is their data 


available because I figure it is a different 


position. He doesn’t make a specific claim 


though but --


 DR. ULSH: Okay. Yeah. We can put that -- let 


me see now. Working in the americium line. We 

can try it. We’ll -- We’ll take a look at it, 

Mark. 

 MR. GRIFFON: It’s not a specific 


(unintelligible). If it’s possible. 


 DR. ULSH: Okay. Comment number 12. Most 


exposed workers were not monitored for neutrons 


and the petition cites Roger Falk who is 

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sitting here at the table, saying that until 


July 1958 the most exposed workers were not 


monitored for neutrons, raising a question of 


how the neutron data and the NDRP study are to 


be used even if the re-reading of the badges is 


accepted as sound. In the -- In the response 


we’re contending that the neutron doses can be 


reconstructed based on neutron dosimetry if 


it’s available as adjusted by the NDRP. And 


that if it is unavailable we can use neutron to 


gamma ratios to calculate neutron doses. 


Regarding the last sentence, the last part of 


the comment, even if the re-reading of the 


badges is accepted as sound, NIOSH is not aware 


of any evidence that would call into question 


the soundness of the re-reads of the NDRP so I 


don’t see this as an SEC issue. However, 


Arjun’s reaching for the microphone. 


 DR. MAKHIJANI: Yeah. No, no. I -- There 


wasn’t any implication that the reading wasn’t 


sound. I just wanted to make sure that that 


wasn’t an issue in this -- in this thing. That 


the only issue in this context was Roger Falk’s 


statement that the most exposed people were not 


monitored. So that whatever the resolution of 

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all the NDRP issues, that should be set aside 


in -- in responding to this. That was the only 


implication that I had comment. But -- But 


the question is I don't know what the origin of 


that statement was and how -- how these -- how 


the neutron co-worker set is to be constructed. 


 MR. FALK: This -- This statement was taken 


from my presentation to the Rocky Flats DOE in 


1994 of the results of the pilot study that we 


did to scope out the -- the nature of the 


neutron dosimetry problems in the ’50s and 


early ’60s. And then also to actually present 


what we needed to do about that. And that was 


the start of the neutron dose reconstruction 


project. And that I think has basically 


addressed all the issues that we found in the 


pilot study. 


 DR. MAKHIJANI: Including -- Including this 


one? Ron -- Maybe Ron knows the answer to 


this. I have not carefully gone over the NDRP. 


But including this problem that the workers 


that were monitored were not the most exposed 


ones? 


 MR. FALK: Yes, because we basically assigned 


what we called the no show dose to the people 

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who were not monitored based on the methods 


that are described in the protocol, especially 


the section -- especially -- especially section 


11 of the protocol. 


 MR. BUCHANAN: This is Ron. Yes, this is 


exactly the question I have of my three 


questions that we were going to get to later; 


this is number one, was addressing the workers 


that were not monitored in the early ’50s which 


were asking folks to -- neutron radiation. And 


I realize, you know, one of the statements is 


that they monitored everybody (unintelligible) 


ten percent of the radiation techs got at that 


time. However, there was only 10 to 18 badges 


each during this seven-year period in the early 


’50s and those (unintelligible) during the 


’56/’57 time frame I believe, that area. And 


so my question is number one I guess 


(unintelligible) here in reconstructed dose for 


these radiation workers in the early ’50s you 


don’t have you’ve got co-worker information 


(unintelligible) badges (unintelligible) 


neutrons. How do we know that -- that they 


didn’t get over ten percent of the -- allowed 


limit because (unintelligible) the way I 

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understand it if you’re going to reconstruct 


(unintelligible) for people that weren’t 


badged, they would get ten percent of their 


(unintelligible) limits or (unintelligible) 600 


a year -- 600 millirem per year. However, you 


might have radiation workers exposed to 


neutrons that weren’t recognized at that time 


that weren’t badged. We could have radiation 


workers that got, you know, more than ten 


percent. How -- How do these workers get 


identified and assigned a dose greater than 


this (unintelligible) values and 


(unintelligible) 


 MR. FALK: What we did is we went back to the 


rosters --


 MR. BUCHANAN: Roger, could you get a mike? 


can’t hardly hear you. 


 MR. FALK: I thought I had a mike. 


UNIDENTIFIED: Get real close. 


 MR. FALK: What we did is we were really 


concerned about the workers in building 71 


which was chemical processing and also the 


plutonium metal working area in the ’50s. And 


what we did is we got the building rosters. 


And also -- also during that time I think 


I 
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essentially all of the workers were monitored 


at least for the gamma exposures. And so we 


did have the gamma data, the whole body 


penetrating gamma. So what we did is we 


applied a neutron to gamma ratio based on the 


chemical processor -- process operators in 1959 


and we used that to -- to -- to then establish 


the no show dose for -- for the building 71 


workers who were not monitored for the 


neutrons. 


 MR. BUCHANAN: And this dose could exceed the 


ten percent of the 600 millirem per year as 


described in the -- the external TBD section 


6.9 seems to limit it to around 1.2 rem per 


year but on an individual case basis. It could 


be higher than that if they were -- were 


exposed to work which was perhaps 


(unintelligible); is that correct? 


 MR. FALK: When we did the NDRP project we did 


not pay any attention to the ten percent. We 


just -- We just multiplied the gamma dose 


which was required for them by the neutron to 


gamma ratio. 


 MR. BUCHANAN: Okay. I can’t -- when the dose 


reconstructor (unintelligible) person -- when 

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the dose reconstructor reconstructs 


(unintelligible) dose, if he could not come 


under the NDRP (unintelligible), what would be 


done about assigning missed dose. 


 DR. ULSH: This is Brant. 


 MR. ROBINSON: This is Al. 


 DR. ULSH: Okay. Good. 


MR. ROBINSON: Based (unintelligible) the NDRP 


study and --


 DR. ULSH: Al? Al? 


 MR. ROBINSON: -- the neutron dose refers -- 


its dosimeter report outside the study that we 


-- we would assume that he did not get any 


neutron dose. So that -- and we -- so we would 


apply that (unintelligible) 


 DR. NETON: Who was that? 


 DR. ULSH: That was Al Robinson. Al, you might 


be on a speakerphone. It’s hard for us to make 


out your entire comment. Could you --


 MR. ROBINSON: Is this better? 


 DR. ULSH: Marginally. 


 MR. ROBINSON: How about this? 


 DR. ULSH: That’s better. 


 MS. MUNN: Yes. 


 MR. ROBINSON Is that better? 

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 DR. ULSH: Yes. 


MR. ROBINSON: Yeah, I’ve had a terrible time 


hearing, too, I’ve had the speaker up to my 


ear. Basically if -- if the worker was not 


included in the NDRP study and there’s no other 


extraneous evidence, you know, that he would 


have had neutron dose then we would apply only 


penetrated photon dose with 600 millirem, if 


there was no other dose for that year. So we 


would rely to a large degree on the NDRP study 


to tell us that that person either had neutron 


dose on either side of -- of some gap that 


might be in there or -- or his work 


location/(unintelligible).


 DR. ULSH: Ron, Ron. 


 MR. BUCHANAN: Yeah. 


 DR. ULSH: We can barely hear you again. Can 


you get closer? 


 MR. BUCHANAN: Okay. Can you hear me now? 


 DR. ULSH: Yup. 


 MR. BUCHANAN: Okay. The NDRP covers 


(inaudible) 


 MS. MUNN: You’re fading in and out again. 


 MR. BUCHANAN: (inaudible) Okay. Can you hear 


me here? 

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 DR. ULSH: Oh, yeah. 


 DR. NETON: Very loudly. 


 MS. MUNN: Very loudly, clearly. 


 MR. BUCHANAN: Okay. I understand that NDRP 


pre-read all the film badges, MDA film that was 


available that’s re-readable whether they were 


plutonium workers or not. Now, I guess where 


I’m still unclear is they -- they didn’t 


(unintelligible) in the early ’50s. So if they 


re-read all of them at (unintelligible) 


acceptable as good, but what about the workers 


in the early ‘50s that did not have MDA plates 


(unintelligible) and they were exposed to more 


than the 600 millirem top? Are you going to 


use -- in the NDRP if you go back and 


reconstruct their -- their neutron dose -- 


excuse me -- photon ratio even if they weren’t 


-- didn’t have mda gamma plates to read? 


 MR. FALK: The answer is yes. 


 MR. BUCHANAN: The answer to that is yes? 


 MR. FALK: Yes, because we would then do the 


no-show dose multiplying their gamma dose by 


the neutron to gamma ratio for that building. 


Now -- Now, the people at Rocky Flats who were 


not monitored for -- for the neutrons were the 

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people in building 81 which was -- which was 


the enriched uranium and also building 44 which 


was the depleted uranium operations. But there 


is no real evidence that there was a 


significant neutron component to their external 


exposures. 


 MR. BUCHANAN: So they would not have a neutron 


dose assigned to them in those buildings? 


 MR. FALK: Yes, that is right. 


 MR. BUCHANAN: Okay. Okay. At this point I 


think that I understand how it was done. I 


would not want to completely sign off if this 


is not an issue, but I would need to -- to 


digest a little further. But I guess at the 


question -- at this time I don’t have any 


further questions. 


 DR. MAKHIJANI: Could I ask, Roger -- Mark, 


sorry. Go ahead. 


 MR. GRIFFON: I was going to say I’m going to 


put that item number 12, Ron, add question 


number 1 into that and make it sort of one item 


on our list, and I’ll -- I’ll say there’s no 


further response because SC&A is still 


reviewing. 


 DR. MAKHIJANI: Yeah. Well, Mark, I think I 

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need a little clarification because I’m looking 


at this Section 11 in the NDRP and I see where 


Roger says how they’re going to fill these gaps 


in the dose, but I still don’t understand what 


was the origin of the statement that the most 


exposed workers were not monitored and how 


filling these gaps actually addresses that 


question at all. If the most exposed workers 


were not monitored are we -- 


 MR. FALK: They were not monitored for the 


neutrons. They were monitored -- 


 DR. MAKHIJANI: For -- For the neutrons. 


That’s what I’m saying. 


 MR. FALK: All right. 


 DR. MAKHIJANI: If the most exposed workers 


were not monitored for the neutrons, you got 


this lead apron problem where the workers were 


wearing the gamma badge under their lead apron, 


so you’re shielding out the low energy gamma 


which is a dominant one from the plutonium. 


 MR. FALK: I’m not convinced we have evidence 


that they -- that they wore the lead aprons in 


the ‘50s however. 


 DR. MAKHIJANI: Well, yeah. I’m just trying to 


put whatever’s on the table so that the issues 

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are at least clear as to the methodology. It 


didn’t seem to me that that issue was brought 


up one way or another here, and if -- I’m just 


trying to understand. It was surprising to me 


to see that statement from you in the petition 


and I don’t know what -- what was the sort of ­

-


 MR. FALK: The -- The --


 DR. MAKHIJANI: -- empirical substance behind 


that statement for you to say that the most 


exposed workers were not monitored. 


 MR. FALK: The basis is that the people, the 


workers who were monitored with the glass 


plates were the building 91 workers, not the 


building 71 workers. And -- And basically 


retrospectively, the people -- the workers most 


likely to have been exposed to the neutrons 


were the chemical process operators, and they 


were in building 71 and that was the basis for 


my statement in 1994 when I was scoping out the 


issue. 


 DR. MAKHIJANI: Okay. So what do we do then 


about the building 71 workers who were the most 


exposed but for whom we don’t have data? 


 MR. FALK: We have gamma data. We multiply 

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that by the neutron to gamma ratio and then you 


have a neutron dose which is -- which is our 


best estimate of their neutron exposure. 


 DR. MAKHIJANI: So then my point here would be 


that it would be crucial to clear up that they 


didn’t have these aprons because your whole 


dose reconstruction method then depends on -- 


on that one fact because otherwise you -- you 


don’t have -- you don’t have -- The 


differential between gamma absorption in the 


apron and the neutron absorption in the apron 


is so big that -- that you don’t have a method 


basically. 


 MR. FALK: Well, now, what we do know and the 


as-found condition when I came to Rocky Flats 


in 1966 was that the -- the -- was that the 


hands-on workers at the glovebox did not wear 


the lead aprons at that time, and it is a 


reasonable -- it is a reasonable extrapolation 


backwards that if they didn’t wear it in the 


mid-‘60s when they had really high -- when they 


had really high gamma exposures except -- and 


especially the soft gamma, that it would not be 


reasonable to actually expect them to have worn 


lead aprons back in the ‘50s. 

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 MR. LANGSTED: And we validated that with an 


interview with Ed Putziere (unintelligible) who 


was the radiation protection manager in 771 


building in those early years and no, lead 


aprons were not used essentially at all in -- 


in 71 in those early years. 


 DR. MAKHIJANI: Yeah. My -- My only -- I 


wasn’t saying that they were or weren’t used. 


I was just saying that that particular issue 


becomes crucial to your dose reconstruction 


method because it’s the only thing that you’ve 


got for that building. 


 MS. MUNN: And it appears they’ve tied that 


down. 


 DR. NETON: Yes. Thank you. 


 DR. ULSH: Okay. We took a brief detour here 


to comment number 1 from the 24th of March set. 


I think we were on number 12. 


 MR. GRIFFON: Yeah. I think we’re -- Well, if 


we’re closed out on that I think we’re on 13. 


 DR. ULSH: On 13. Okay. Let me see if I can 


get my head back on track here. Oh, yeah. 


This was another question. Roger, don’t go far 


from the microphone -- about -- under the 


heading, Neutron Badge Reading Was Defective. 

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And the comment deals with a page from the 


petition that says -- that shows that zero 


entries and neutron dose readings dropped from 


95.6 percent in 1961 to 56 percent in 1962 and 


the comment goes on to say that this raises the 


issue of quality of the badge readings in the 


earlier period. And this has been acknowledged 


by NIOSH and the NDRP study was put in place to 


address this issue. We agree that was the 


genesis. One of the reasons behind the NDRP 


issue and the NDRP did address those earlier 


reads, so I -- I think we’re okay here and 


NIOSH or Arjun is nodding his head, so I think 


we’re okay. 


 DR. MAKHIJANI: I got -- Ron -- Ron is the one 


that would know but I think -- I think that -- 


that seems --


 MR. GRIFFON: Ron, did you have a comment on 


this? 


 MR. BUCHANAN: Well, I’d like to think that -- 


Well, I read the NDRP several times. We have 


not had formal review of that by SC&A. It’s a 


pretty complex, lengthy document and I’ve 


looked over it but I have not made a -- a 


definite statement on, you know, had a review 

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of that. Now, some of the questions in number 


2 and 3 of that list of questions, you know, 


relate to it. We have done a complete 


examination of NDRP by SC&A. 


 DR. ULSH: Okay. 


 MR. GRIFFON: I think that and the previous one 


are still open items, but there’s no further 


action by NIOSH on the part of this 


(unintelligible) 


 MR. BUCHANAN: That’s correct. 


 DR. ULSH: Okay. Comment number 14 is under 


the heading of Post-1991 worker monitoring was 


not according to criteria for security guards. 


And the situation described in the petition 


here is that during that time period, post1991, the only workers who were badged were 


those who were thought to have the potential 


for a hundred millirem exposure per quarter or 


more, and the DNFSB found that security guards 


had potential for greater than that and they 


were unmonitored. If that situation were to 


occur, it -- I think NIOSH would approach it as 


unmonitored radiation workers and we would 


handle it using the co-worker model, do a coworker dose reconstruction. So again I think 

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that we perhaps don’t have an SEC issue here. 


 MR. GRIFFON: I -- I wasn’t clear on your 


response. Are you saying that if that 


situation occurred, I mean this is specifically 


for security guards for this specific time 


period. Have you looked at the, you know, the 


report and is it -- are you in agreement with 


that report? And if it did occur, if you’re in 


agreement with the report. 


 DR. ULSH: Yes. For such a situation, and it’s 


described in the -- in the DNFSB report. The 


way that we would handle that would be to treat 


them as unmonitored radiation workers and do a 


co-worker data dose reconstruction. So Mark, 


would that fall into the category of our action 


has been completed? 


 MR. GRIFFON: I think so, and you -- we don’t 


have a co-worker model to look at, do we? 


 DR. ULSH: No. Right. We talked about that 


earlier when we were on the matrix. 


 MR. GRIFFON: So in other words a co-worker 


approach would be used to be determined later, 


right? 


 DR. ULSH: Right. 


 MR. PRESLEY: (Unintelligible) 

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 MR. ROBINSON: This is -- This is Al Robinson 


again. You know, one thing, you know, on the ­

- on the dose reconstruction to date -- now, we 


can apply the co-worker data -- 


UNIDENTIFIED: Could you turn that down just a 


little bit? We’re having some complaints. 


 MR. ROBINSON: -- gamma exposure, but I would 


have applied 100 millirem per year as stated 


here to a security guard, you know, unless 


there was some evidence that gives any 


dosimeter -- dosimetry reports said, you know, 


he had a lot higher dose or had been involved 


in a -- in an incident or something. But if he 


was just a routine worker who was not monitored 


in that post-1991 period, then we would have 


felt that it fell under the admonitions there 


and given him 100 millirem. 


 MS. MUNN: I can’t hear him. 


 DR. NETON: A little bit louder then. 


 MR. GRIFFON: That’s interesting because that’s 


exactly what I was thinking about, will the coworker model necessarily end up assigning 100 


millirem? 


 DR. ULSH: No. 


 MR. GRIFFON: Or greater. It wouldn’t 

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necessarily. 


 DR. ULSH: The co-worker model would not rely 


on the 100 millirem criteria at all. 


 MR. GRIFFON: Right. 

 MR. ROBINSON: Right. 

 MR. PRESLEY: Question. If you did the coworker model would you pick a co-worker model 


from the area where the guard claimed to have 


been and not another guard? 


 DR. ULSH: When we do co-worker dose 


reconstructions, we don’t apply the co-worker 


information from a specific individual. 


Rather, we build our co-worker model on 


distributions of all the monitored workers. So 


we would select a claimant favorable percentile 


value for those years, and it would cover the 


entire population of monitored workers. 


 DR. NETON: I think this is --


 MR. GRIFFON: We have to wait to see the coworker models. 


 DR. NETON: Yeah. I think we need to develop 


the co-worker model. The security guards to me 


seem to be an issue -- a situation where we 


might need to take a little special 


precautions. It occurs to me that, you know, 

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if we applied the 95th percentile of 


distribution, we may overestimate these workers 


and in fact --


 MS. MUNN: Significantly. 


 DR. NETON: -- maybe that even the 50th 


percentile. 


 MS. MUNN: Significantly. 


 DR. NETON: So it appears that the true 


exposure may be somewhere between this -- 


 MR. GRIFFON: Right. 


 DR. NETON: -- 100 millirem and the 50th
 

percentile. We -- We would need to take a 


slightly closer look at that to figure out 


where it would --


 MR. GRIFFON: That’s why I was -- I was asking 


first if you’re in agreement with the DNFSB 


report (inaudible) 


 DR. ULSH: I don’t -- I don’t have any reason 


to fault or to doubt the DNFSB report at this 


time. 


 MR. ROBINSON: Because the other, you know, the 


other issue is like any other -- like any other 


dose reconstruction. You know, if there was a 


year or a couple of years, then we would look 


at the dose on either side, so often you could 

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tell whether or not there was (unintelligible) 


gotten a higher dose. 


 DR. NETON: One thing I’m not clear on is this 


-- this comment says that 100 millirem exposure 


per quarter. My recollection of 


(unintelligible) 4835 is that it was 100 


millirem per year. I’m not sure why Rocky 


Flats would adopt something that would be 


inconsistent with the regulations. We need to 


take a look at that as well. 


 MR. GRIFFON: Could it have been -- 


 DR. NETON: It could just be a typo. 


 MR. GRIFFON: -- probably. 


 MR. LANGSTED: You’re correct, Jim. The 


criterion would be 100 millirem per year -- 


UNIDENTIFIED: A year. 


 MR. LANGSTED: -- for badging. 


 MR. GRIFFON: For (unintelligible) 


DR. NETON: Actually, the -- I think the 835 


interpretation is the internal/external 


exposure were independent source terms. At 


least that’s the way most sites interpreted it. 


 MR. GRIFFON: Oh, yeah. We’ve been around -- 


I’ve been around the block now. Yeah, I think 


you’re right though. Yeah. 

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 DR. NETON: In fact -- Well, yeah. 


 MR. GRIFFON: But anyway, that -- Yeah, so I 


think your -- we ought to respond at this 


point, I think. 


 DR. NETON: I think we do, too. 


 MR. GRIFFON: How it’s going to be handled in 


terms of co-worker model. 


 DR. NETON: Well, I think Brad is actually 


right that this is really an interpretation 


issue and not a -- a bounding dose calculation 


issue for SEC implications. This is -- This 


is rather where one fixes the set point for 


reconstructing what -- what would be 


unmonitored dose in this case. 


 MR. GRIFFON: I would agree. 


 DR. ULSH: Okay. The next comment is comment 


number 15, and this is -- this is an involved 


comment. It’s going to take a little time. 


don’t know where we stand in terms of breaks, 


but we’re going to be here for a while if we 


bump into 15. 


 MR. GRIFFON: Well, I’m certain we could get 


through, but maybe we should take a break at 


this point. 


 DR. WADE: Okay. If we got some heavy -- 


I 
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Let’s take a very quick five minute stretch 


break and --


 MR. GRIFFON: Take five. 


 (Whereupon, a recess was taken from 3:40 p.m. 


to 3:50 p.m.) 


DR. WADE: Okay. We’re back in session. 


 DR. ULSH: Okay. I think we left off with 


comment number 15, and this comment is under 


the heading of many incidents were not reported 


or recorded. And this comment cites some pages 


in the petition that actually constitute a 


consent order between the Department of Energy 


and Kaiser Hill. I’ve scanned and put this 


into this handout. It starts on page 19 and 


I’d like to walk you through this consent 


order. If you look at near the bottom of page 


19, you’ll see a paragraph that begins internal 


intakes of radioactive material occurred with 


two workers who were doing some underground 


tank remediation activities. This is the first 


example that’s dealt with in the -- in the 


consent order, and this occurred in 1996. What 


happened here was that due to a number of 


issues dealing with regulatory compliance 


primarily, the consent order describes some 

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failings on Kaiser Hill’s part to maintain 


ALARA. And what happened was that these 


workers got some intakes; however, this was not 


discovered at the time of the incident. 


Rather, it was discovered through routine 


bioassay for one worker and by a special 


request bioassay for the second worker. That’s 


described on Page 20. Again, I don’t -- I 


don’t think that this actually demonstrates 


issues that were unreported. In fact, this is 


exactly the opposite. This issue was 


discovered and -- and investigated and included 


in a consent order. Rather, it shows that 


intakes are not always recognized at the time 


that they occur and that’s why you have a 


routine bioassay program. So I think that 


that’s really all I want to say about that 


particular example. The next incident -- 


 MR. GRIFFON: Again, were -- were all workers 


under the routine bioassay program? 


 DR. ULSH: Were all workers under the routine 


bioassay program in 1996? 


 MR. GRIFFON: (unintelligible) 


 DR. ULSH: I’m looking at my -- at my subject 


matter experts for the answer to that question. 

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 MS. MUNN: Bioassay programs? 


 DR. NETON: This is Jim Neton. I think that in 


-- by 1996 the requirement was to have all 


workers with the potential to receive 100 


millirem --


 MR. GRIFFON: Right. 


 DR. NETON: -- on some type of bioassay 


program. So it probably wasn’t all workers, 


but --


 DR. ULSH: But these workers were. 


 MS. MUNN: Yeah. 


 DR. NETON: Right. 


 MS. MUNN: (unintelligible) pretty serious. 


 MR. GRIFFON: You’ve been answering several of 


these questions with the fact that well, that’s 


why you have bioassay programs but you get -- 


The question is really more complicated if the 


individuals involved in the incident were not 


on the bioassay program or never were on the 


bioassay program. 


 DR. ULSH: But there’s no evidence of that 


presented here, Mark. This -- This consent 


order deals with an incident where workers who 


were on routine bioassay programs had an 


intake. So I don’t think that this consent 

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order can be used as evidence that the opposite 


 MR. GRIFFON: Well, there was one person at 


least that indicated -- I haven’t read it yet, 


but the one person indicated he had requested a 


bioassay but he was not on a routine program. 


 MS. MUNN: Well, the consent order says uptakes 


were discovered through routine bioassay. 


 DR. ULSH: For one worker. 


 MS. MUNN: For one. 


 DR. ULSH: And then by special request for 


bioassay --


 MS. MUNN: Requested by the other. 


 DR. ULSH: -- by the second worker. 


 MS. MUNN: Uh-huh. 


 MR. GRIFFON: Right. So you self-identified, 


and if that’s fine for this situation. I guess 


that’s just what I’m asking, both what the 


percentages were for -- because I think you 


have people -- I think it’s just a question of 


how do you handle the unmonitored and what 


fraction of people fall into that category, I 


guess is what I’m getting at. 


 MS. MUNN: Does --


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people --


 DR. NETON: Yeah. I mean we took -- 


 MS. MUNN: (unintelligible) requested 


(unintelligible) 


 MR. GRIFFON: -- were either involved or not 


involved in it. 


 DR. NETON: Typically, Mark, as you might 


remember, the way we handle co-worker data for 


internal exposures are that workers who were 


judged by NIOSH to have -- were not monitored 


and should have been monitored -- 


 MR. GRIFFON: Right. 


 DR. NETON: -- because they had high potential, 


would receive the 95th percentile -- 


 MR. GRIFFON: Right, because --


 DR. NETON: -- the co-worker model. 


 MR. GRIFFON: -- it might -- maybe 


(unintelligible) the model (unintelligible) 


 DR. NETON: Right. And then if in this case, 


you know, it depends on how this worker, what 


his job function was. But if it was judged 


that he probably didn’t need to be monitored on 


the program, he would have received the 50th 


percentile. Then there’s a further cut point 


for someone who really had almost no potential, 

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which would be the secretarial/administrative 


types. 


 MR. GRIFFON: Right. 


 DR. NETON: So that’s -- that’s how it would be 


handled. 


 DR. ULSH: And I -- Mark, I -- I -- The 


consent order --


 MR. GRIFFON: That’s what I assume you said, 


the co-worker was monitored. 


 DR. NETON: Yeah. 


 DR. ULSH: Well, the consent order does say 


that for the second worker it was a special 


request for bioassay; however, it doesn’t say 


that he wasn’t on routine bioassay in addition. 


It’s just that it was discovered by the special 


request. 


 MR. GRIFFON: Okay. 


 DR. ULSH: Okay. The next example begins at 


the bottom of page 20 of the handout, and this 


-- this details a number of individuals in ‘96 


and ‘97 who were not monitored and later it was 


discovered that they actually did receive a 


dose while they were not monitored. And keep 


in mind, though, that this comment is under the 


heading of incidents that were not reported or 

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-- I want to get the right word -- not reported 


or recorded. Okay. So this incident we’ve got 


unmonitored individuals receiving dose, 


however, I would direct you to the middle of 


the -- the bottom paragraph on page 20 where it 


talks about SSOC, Safe Sites of Colorado. They 


initiated an investigation and dose 


reconstructions began for these individuals in 


mid-September of 1997. So these -- these 


incidents are not examples of -- of instances 


that were not reported. On the contrary, they 


were investigated. The next example is not 


terribly informative. I don’t think it’s being 


advanced in relation to the SEC petition. 


That’s at the top of page 21. Deals with a 


sealed source custodian conducting an inventory 


and he didn’t receive the training that he 


should have received. I don’t think that 


that’s really an issue that we need to go into, 


although I will if anyone wants to. Okay. 


Finally, we get to the conclusions, section 3. 


It’s labeled section 3 on page 21 and I’d like 


to just read that to you. It says that DOE has 


evaluated the results of the investigations 


conducted by Kaiser Hill and has concluded that 

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the findings and conclusions with respect to 


these incidents are comprehensive. DOE has 


concluded that these investigations fully and 


accurately disclose all relevant facts 


including the identification of potential 


violations of nuclear safety requirements. It 


goes on and talks about in the areas of 


radiation protection and quality assurance and 


objectively assesses the actual potential or 


programmatic safety significance of these 


potential violations. This consent order does 


not show events that were unrecorded and 


uninvestigated. It shows exactly the opposite, 


and the conclusions stated here, I -- I think 


put their interpretation on there. Comment --


section 4 says that DOE acknowledges Kaiser 


Hill’s -- Kaiser Hill’s aggressive and 


comprehensive investigation to determine the 


causes of these incidents and open an objective 


assessment of the operational shortcomings 


involved. DOE has also evaluated and agrees 


with the adequacy of the corrective actions. 


don’t see this as evidence for many incidents 


going unreported and uninvestigated. 


 MR. GRIFFON: Okay. I mean that was a thorough 


I 
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analysis of -- of -- I’m not sure where the -- 


that list is from. Is that table E-5 or -- 


 DR. ULSH: This --


 MR. GRIFFON: -- I have all the references of 


all the --


 DR. ULSH: Let me go back to the comment. 


 MR. GRIFFON: -- but they were all in the ‘90s, 


right, meaning --


 DR. ULSH: Well, yeah. I was addressing -- 


 MR. GRIFFON: -- I’m going -- I’m going to the 


first section of the comments, number 15 says 


the petition claims (reading) “throughout the 


history of the site it was common practice for 


incidents in the workplace be handled at the 


floor or building level and not reported.” I 


don’t know if you have a response to that part 


of it. 


 DR. ULSH: I think that that is true, Mark, 


that there were incidents that were at the 


discretion of the floor super-- of the -- of 


the management that were to be decided what was 


a sufficient magnitude incident to report. 
I 


think that that’s probably true. 


 MR. GRIFFON: The real response there is that 


we’ll still capture the dose on the routine or 

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co-worker model, right? 


 DR. ULSH: Exactly. 


 MR. GRIFFON: Routine bioassay or co-worker 


model. 


 DR. ULSH: Exactly. 


 MR. GRIFFON: And Jim’s explanation -- I mean 


we haven’t seen a co-worker file yet but if it 


holds true that we -- if they were supposed to 


be -- should have been monitored or -- so we 


have a 95th percentile approach. 


 DR. ULSH: Right. 


 MR. GRIFFON: Okay. 


 DR. ULSH: Okay. Unless anyone has any 


questions or wants some follow-up, we’re up to 


almost the end here. All right. Comment 


number 16 on this data set, and that’s on page 


24. I had a little trouble following this 


comment and -- and I might have misinterpreted 


it. It appears to be concerned with the 


estimation of doses from material that was 


inhaled and then cleared out of the lungs and 


swallowed, ingested. That’s the way I 


interpreted the comment, and I -- and it asks 


how we would handle this issue. And my 


response is the ICRP models take this 

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phenomenon into -- explicitly into account. 


They do -- ICRP 66 does consider material 


that’s cleared from the lungs into the GI tract 


and so the models that we use handle the 


situation. Maybe I misinterpreted the comment; 


I don’t know. 


 MR. GRIFFON: You know, it seems to be asking 


about both. Can someone read the comment? I 


don’t have the full comment or the full -- 


 DR. ULSH: Yeah, because it -- Well, it says 


that workers ate in workplaces and that’s -- 


 MR. GRIFFON: I think it boils down to Arjun’s 


review, right? 


 DR. ULSH: Pardon? 


 MR. GRIFFON: Arjun, can you speak to that 


comment? 


 DR. MAKHIJANI: I was looking at a previous one 


still. Sorry. I missed it. 


 DR. ULSH: Comment number 16, Arjun. 


 DR. NETON: The one about ingestion, 16. 


 DR. ULSH: We were -- We -- It seems to be 


that this comment’s concerned with how you deal 


with material that was inhaled and then cleared 


out of the lungs and swallowed, ingested. Is 


that -- Is that correct? 

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 DR. MAKHIJANI: Yeah, I -- I think --


 MR. GRIFFON: Eating in the workplace 


(unintelligible) 


 DR. MAKHIJANI: Yeah, the -- the -- the problem 


would be, you know, if there are ingestion 


doses that are significant and -- and in light 


of the low systemic doses from the inhaled 


component, could it be that it might be higher 


doses or if -- if bioassay data were 


reinterpreted as ingestion doses, whether they 


might give you a different result or -- or how 


you calculate that component. 


 DR. NETON: Yeah. It -- It appears to me 


looking at the paraphrase of the issue raised, 


that there are two questions here. One is --


 DR. MAKHIJANI: Right. 


 DR. NETON: I agree with Mark on that. One is 


that there was ingestion via inhalation and 


Brant’s answer is right on target here in 


relation to that, that any ingestion as a 


result of an inhalation dose is explicitly 


dealt with in the ICRP models. I think we all 


agree with that. Now when they -- when they 


assert here that workers ate in the workplaces 


and how the bioassay data would be interpreted. 

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In light of this problem an ingestion may have 


occurred via re-suspension, that -- that -- 


well, re-suspension would be -- 


 MR. GRIFFON: All it did was provide that re-


suspension would be still be inhalation. 


 DR. NETON: Yeah, re-suspension would be re-


inhalation so --


 MR. GRIFFON: Yeah. 


 DR. NETON: -- really then we’re back to 


workers ate in the workplaces and potential 


ingestion pathway, and I don’t recall what -- 


how in -- how specifically the ingestion 


pathway was dealt with in the Rocky Flats site 


profile. And my recollection is that there 


were some comments by SC&A on that issue. 


UNIDENTIFIED: Something I recall. 


 DR. NETON: And -- And I’m at a loss as to 


how to -- how to -- how to bracket that. I 


think -- I think the -- you know, plutonium 


itself has a very low gastrointestinal 


absorption factor. I think that’s well-


recognized. But we need to -- I think we need 


to reevaluate this comment in light of the fact 


that, you know, they are -- I think they are 


sort of asking about how we’re dealing with 

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ingestion doses and from eating in the 


workplace and we -- we need to -- we need to 


re-look at that I think, and -- and address it. 


 DR. MAKHIJANI: Yeah. Just for clarification, 


Jim, I did not go back to our -- to the site 


profile or the site profile review. As you can 


see, sometimes these were quick paraphrases and 


 DR. NETON: I understand. 


 DR. MAKHIJANI: -- thank you for making -- 


making them more accurate as you went. 


 DR. ULSH: Well, I completely understand, 


Arjun. Some of my responses were pretty quick, 


too, so -- in fact, all of them were. Okay. 


Number 17. This is length of the work week. 


Worker alleges that the work week was logged as 


40 hours when it was 45 hours. This might fall 


into the category of an issue that may not have 


SEC implications, especially at Rocky Flats 


because this -- this consideration -- 


 MR. GRIFFON: (unintelligible) 


 DR. ULSH: Right, exactly. This would be 


important if we were doing a source term 


calculation perhaps. We don’t propose to do 


that at Rocky Flats. We were going to rely on 

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individual dosimetry results, so I don’t -- 


Okay. That’s okay, Arjun? 


 DR. MAKHIJANI: Yeah. 


 MR. FITZGERALD: Just a -- That’s closed. 
I 


want to go back to 15, and we did have a issue. 


Item 15 on the original matrix. 


 DR. ULSH: Oh. 


 MR. FITZGERALD: And I’ll just read the NIOSH 


response, which I think is where that was left 


in terms of ingestion. Discussion of the 


ingestion pathway will be -- will be added to 


the TBD. So I guess that infers that it wasn’t 


there. 


 DR. ULSH: Right. 


 MR. FITZGERALD: And the ingestion pathway, 


except as a clearance process for inhalation 


intakes is not significant for workers in 


plutonium-enriched uranium process areas 


because eating and drinking in the process 


areas were strictly forbidden. It is not clear 


how strictly the rules were enforced for 


depleted uranium areas. This issue will be 


reviewed. That’s what we had -- 


 DR. ULSH: Okay. 


 MR. FITZGERALD: When we left it in the site 

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profile. 


 DR. NETON: I thought that was my recollection. 


 DR. ULSH: Okay. That was the big data, the 


big comment set. 


 MR. GRIFFON: Now we go on to March 24th, is 


that --


 DR. ULSH: Yes. 


UNIDENTIFIED: Yeah. 


MARCH 24TH COMMENTS


 DR. ULSH: Now we’re on to March 24th. I think 


we’ve talked about comment number 1. 


 MR. GRIFFON: Right, under previous discussion. 


 DR. ULSH: Right. So now we get into comment 


number 2. This, Mark, to track this back, I 


think it’s -- the first incarnation was we were 


going to provide plutonium tetrafluoride 


calibration data, and we referred SC&A to Mann 


and Boss. They have reviewed Mann and Boss and 


then these questions result from that review. 


 MR. GRIFFON: Does it go back to number 6? 


 DR. ULSH:: Oh --


 MR. GRIFFON: Or should number 6 be original 


(unintelligible) --number 6 -- because I have 


to put this together later. 


 DR. ULSH: Yeah, let me look, Mark. 

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 MR. GRIFFON: I think it’s 7. Maybe it’s 7. 


 DR. ULSH: It’s matrix issue number 7, action 


item number 1 from the February 27th matrix. 


 MR. GRIFFON: Right. 


 DR. ULSH: So that’s kind of the pedigree of 


this issue. Okay. When we referred SC&A to 


the Mann and Boss article, we were doing that 


to provide details of the calibration sources 


that we used in the NDRP. It’s -- What we’ve 


concluded based on the time estimates that were 


given in Mann and Boss for reviewing these -- 


the NTA films is that they focused on the large 


obvious tracts. In contrast, the NDRP focused 


not only on the large obvious tracts, but 


tracts as small as three to five grains. And 


so they were much more sensitive -- the NDRP 


results were much more sensitive to the low 


energy neutrons, and what the NDRP did to deal 


with this calibration issue was they exposed 


four films -- and Roger has corrected me in my 


response on page 3. I said they were four 


replicate films. In fact they were not 


replicate films. They were four films over a 


range of doses. They were exposed to the bare 


source, which is shown in Mann and Boss. They 

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were also exposed to the most moderated neutron 


source, and they were read blindly. And what 


they found was that there was an insignificant 


difference between the two. The moderation 


didn’t affect the sensitivity of the films. 


The difference was only about two percent, 


therefore, they concluded that there was no 


significant difference and they used the 


overall calibration factor. Now, Roger, 


correct me if I said anything wrong there. 


 MR. FALK: That is -- That is correct. 


 DR. ULSH: That’s -- Okay. And that’s 


described in section 8 of the NDRP, page 15. 


 MR. BUCHANAN: No, this is wrong. Okay. I 


have a question on that. Now, I understood the 


last time we talked, Roger said they did not 


re-expose any -- any film there in the NDRP 


process. Is that correct or incorrect? 


 MR. FALK: I did not expose any films for the 


NDRP project. These were the calibration films 


that I had exposed in 1967 and ‘68 during the ­

- during the lifetime when I was basically 


overseeing the neutron film reading at that 


point. So these are basically archived films 


that I had essentially archived from those 

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early times, and then I constructed the -- the 


calibration sets for the film readers for the 


NDRP projects from those old calibration films. 


And I -- And then I put in each set, four 


films of the bare moderation and four films of 


what we called the demoderation, which was that 


-- was that -- the -- the -- which was the 


thickest moderation of the -- of the Mann and 


Boss set. So we had the unmoderated and then 


we had the heavily moderated, and what we did 


is that is that all of the film readers for the 


neutron dose reconstruction project blindly 


read those films to establish what the millirem 


per track would be for their readings. And 


then at the end of the project, I basically 


took all their data and then did a comparison 


of their calibration factors for the -- for the 


unmoderated plutonium fluoride source and I 


compared that to their own calibration factors 


for the moderated source and did an overall 


composite and found only a -- found only a two 


percent difference. Therefore, I said there 


was no significant difference. We can use the 


calibration set based on the composite for the 


final analysis of the neutron doses for the 

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NDRP project. 


 MR. BUCHANAN: So you’re saying that when you 


reread the older calibration film, that you 


found out that the millirem per tract or per 


square millimeter was the same in heavily 


moderated as it was with the bare neutron 


source. Is that what you’re saying? 


 MR. FALK: Yes. 


 MR. BUCHANAN: And you’re saying that Mann and 


Boss in the past had not read the shorter 


tracks and so they’d seen the difference and 


that explains why they’d seen the difference 


and you didn’t? 


 MR. FALK: I am basically speculating that to 


be the case and I’m not even sure that Mann and 


Boss actually read those. I am thinking it’s 


more likely that the film readers -- that the 


film readers of that era read the films and 


they would more -- most likely read -- most 


likely read only the obvious tracks and not the 


-- and not the shorter less obvious tracks. 


That -- That is my working hypothesis as to 


why there is that difference. 


 MR. BUCHANAN: This one is very different in 


the length of the track from the moderated to 

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the unmoderated. Maybe you counted the same 


number of tracks per -- per millirem. Were 


there difference in the length like for say, 


the unmoderated, were the lengths of the tracks 


longer generally on an average then say the 


moderated source? 


 MR. FALK: I am visualizing that, and also I 


had pondered that. But I would say that --


that a film reader would not be able to tell 


just by looking at the films which one was 


moderated and which one was not. It is not 


obvious to me. 


 MR. BUCHANAN: Okay. Yeah, I see what you’re 


saying. It kind of goes against the grain of ­

- of most neutron dosimetry and so that has to 


consider whether, you know, what would be -- be 


scientifically tolerant as compared to other 


information that’s out there. I think I follow 


what you’re saying you did now. I wasn’t sure 


from the NDRP. Like I say, I haven’t 


scrutinized it page for page, but I understand 


what you’re saying at this point. The second 


question then, in -- in evaluating the neutron 


fields at Rocky Flats, so at this point say we 


accept the fact that the neutron reader, the 

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film readers read the tracts equally well from 


-- the calibration factor is the same whether 


you use the moderated or the unmoderated 


source, which I think it was stated as 1.4 MeV 


for the unmoderated and .15 MeV average 


apparent energy for the moderated. Those did 


cover all the reasonable neutron spectrums at 


Rocky Flats through the years, so it’s going to 


be applying it to all situations through all 


times at Rocky Flats and so apparently you feel 


that this covers all the situations that would 


reasonably exist. 


 MR. FALK: It covers all the film situations in 


the ‘50s and ‘60s. I have not -- I have not ­

- I have not extrapolated that into the later 


years because we’re using the -- we’re using a 


different system. We’re using the -- the -- 


the TLD system after that. 


 MR. BUCHANAN: Yes, okay. Right. I should be 


-- I should have stated up through the MDA. 


 MR. FALK: Yes. 


 MR. BUCHANAN: Does anybody else have any 


comments on that question? 


 DR. MAKHIJANI: Yeah, this Arjun. If I -- If 


I recall, the average moderated energy is .15 

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MeV. Is that right, Roger? 


 MR. FALK: That is the measurement that Mann 


and Boss --


 MR. BUCHANAN: Yeah, right. 


 MR. FALK: -- had reported. 


 DR. MAKHIJANI: So I’m -- I’m just wondering. 


I know you feel the uncertainties are low, but 


what we’ve got is really a measurement that’s 


heavily weighted in the high energy spectrum, 


or extrapolating because we know the spectrum 


of the moderated neutrons; is -- is that right? 


 MR. FALK: We don’t know the spectrum of the 


moderated neutrons. We know the spectrum of 


the unmoderated -- we know the spectrum of the 


unmoderated neutrons for -- for a plutonium 


fluoride source based on spectrum in the 


published literature that I don’t know the 


reference to at this point. 


 DR. MAKHIJANI: Yeah. And -- And how -- how 


are we then calculating the spectrum of the 


unmoderated neutron --


 MR. FALK: We aren’t calculating -- 


 DR. MAKHIJANI: -- of the moderated neutrons? 


 MR. FALK: We aren’t calculating the spectrum. 


The way that I described it in the Boston 

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meeting is what we did, or -- or what I did is 


we had the source term for the plutonium 


fluoride source as given to us by calibration 


at -- at the Los Alamos graphite pile. We can 


then calculate the -- the -- the neutron dose 


rate at a certain distance based on the 


spectrum and based on the -- and based on the 


source term which was called -- which was 


called the Q value for the unmoderated. Then 


we took the Henkins ten-inch sphere neutron 


dose rate meter and calibrated that to the 


unmoderated source. Then we put the moderator 


around the source and measured the dose rate 


from that moderated source, so -- so the -- and 


so the Henkins ten-inch sphere became a 


secondary transfer standard and that’s how we 


determined the -- the dose rate at that same 


distance for the moderated source. 


 DR. MAKHIJANI: So in effect you have -- you 


have a spectrum for the moderated source? 


 MR. FALK: We have a spectrum, but we do not 


have it quantified. 


 MR. BUCHANAN: You have an effective average 


energy, not a detailed spectrum; is that what 


you’re saying? 

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 MR. FALK: We don’t go through that step. We 


go straight from the dose rate measured by the 


ten-inch sphere meter calibrated to the dose 


rate calculated for the bare source at the same 


distance. So we have a transfer standard in 


that -- in that instrument. 


 DR. MAKHIJANI: Okay. I’ll -- I’ll have to 


absorb this like sort of a dose almost. 


 MR. FALK: Right. 


 DR. MAKHIJANI: But what -- what’s the 


uncertainty between, you know, that’s created 


by -- by doing it this way rather than knowing 


the spectrum of the moderated neutrons? I mean 


that’s I guess what I’m getting at. 


 MR. FALK: It is hard to know that spectrum. 


The basic technique at that time was a multi-


sphere type of a system which was still very -- 


which was still very primitive just to -- just 


to go through that secondary step, and why do 


that when you can go straight to a dose rate 


measured by the instrument which is -- which is 


touted as a rem meter and was a standard for 


all field surveys at that time. 


 MS. MUNN: (unintelligible) 


 DR. ULSH: Is -- Is there anything else on 

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comment number 2? 


 MR. BUCHANAN: No, and the -- we already 


discussed the -- the NTA calibration -- site 


calibration earlier so we don’t have to address 


that last sentence then. 


 DR. ULSH: Okay. Folks, we’ve almost made it. 


We’re on the last comment, comment number 3. 


 MS. MUNN: (unintelligible) 


 DR. ULSH: That’s 19 -- The comment concerns 


1970 neutron data, and that was a strange year, 


1970 was. What you have to consider is that 


there are essentially three time periods when 


we consider neutron doses at Rocky Flats. The 


earliest is 1952 through 1969, which was 


covered by the NDRP. Now, the NDRP did 


actually look at a few field films that were 


available in 1970. I’m going to rely on Roger 


to fill in the holes in my -- my account here. 


As I understand it there were films, a limited 


number of films in 1970 and those were for the 


workers that were most exposed. Is that 


correct, Roger? The chem ops in ‘71 


(unintelligible) 


 MR. FALK: All of the workers in the primaries 


were monitored with the films. Most of those 

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were not archived to be available to be read by 


the NDRP project. Only the -- only the films 


essentially for the process operators and a 


couple other higher exposed groups were 


available to be read by the NDRP project. 


 DR. ULSH: Okay. So that’s the first time 


period. The middle time period spans 1970 to 


1976 and during that time period, neutron and 


gamma doses were combined into one value which 


was named penetrating dose. And then you have 


the third time period, and that’s from 1977 


forward, and we have calculated a neutron to 


gamma ratio from that time period. And what we 


did was we extrapolated backwards. We 


extrapolated that neutron to gamma ratio 


calculated from 1977 forward. We’ve applied 


that to the 1970 to ‘76 time period, and the 


reason that we did that was because both of 


those time periods from ’70 to ’76 and ‘77 on 


were in the TLD era, whereas before, in the 


period that the NDRP covered, we were in the 


NTA film era. So we thought that it would be 


more appropriate to use a neutron to gamma 


ratio calculated with TLD’s for that middle 


time period. Now, what I want to emphasize is 

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that during that time period when we had the -- 


only the penetrating dose, essentially we can ­

- one approach that we have used in the past is 


that we’ve double-dipped. We’ve applied -- 


Since we can’t say how much was neutron, how 


much was gamma, we apply it to both. And that 


is, we contend, claimant-favorable. 


Alternatively, we could apply it all to 


neutrons or all to photons, whichever is 


claimant-favorable. And Al Robinson, are you 

still online? 

 MR. ROBINSON: Yes. Yes, I am. 

 DR. ULSH: Okay. So you jump in and correct me 


when I’m going astray here, but that’s how we 


handled the 1970 time period. We applied to 


neutron to gamma ratio calculated in the later 


time period, so Arjun or Ron, does that answer 


your questions on that? 


 MR. BUCHANAN: Well, the question I have is 


that in 1970 -- and I understand that that’s 


what you was planning on doing; however, if 


that -- in the NDRP in section 11.5 says that 


the gamma dose could not be consistently or 


accurately discerned from the data on the gamma 


TLD worksheet. And so my concern was how did 

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we apply it to a gamma ratio if we don’t know 


the gamma dose in all cases. 


 MR. FALK: The answer is that -- that the NDRP 


project did not attempt to -- to actually 


assign a notional dose for the workers in the 


year 1970, not because of the gamma issue but 


because we couldn’t identify the gaps because 


we could not -- we could establish from the 


worksheets available a -- we could not 


establish a coherent timeline for those workers 


to know when there were gaps and when -- and 


when there were not gaps. Actually, the issue 


is somewhat moot because I don’t think there 


were likely many gaps because -- because 


workers were actually monitored for the 


neutrons in that time period. Then -- Then --


Then, also the issue with the gamma doses from 


the TLD’s is the fact that the doses were not 


calculated by the technicians on the 


worksheets. Rather, they were calculated by 


the mainframe based on the crystal readings. 


And therefore, we -- therefore, we didn’t have 


the information on -- on the worksheets that 


would allow us to essentially reconstruct what 


the IBM mainframe would have called their gamma 

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dose just from the crystal readings. And since 


we couldn’t establish the coherent timeline for 


them, it was a moot issue anyway because we 


didn’t bother trying to go through that effort 


to then recalculate the gamma doses if we 


weren’t going to be able to do the notional 


dose anyway. So basically the scope of the 


NDRP project did not extend into 1970 except 


for the films we had available to be reread. 


 MR. BUCHANAN: Okay. So it seems you’re saying 


that the gamma dose is available on the 


mainframe and so that’s not what it’s referring 


to there in 11.5, that the workers’ records 


have the gamma dose reported; is that correct 


for 1970? 


 MR. FALK: Yes, that is correct. 


 MR. BUCHANAN: Okay. So that -- that clarifies 


a lot of issues. Okay. And -- And then the 


other last issue was in the -- in the OTIB 50 


it states that -- it talks about NDRP neutron 


dose for 1970, and I -- if I understand you 


right, you’re saying that there are -- you did 


a few re-reads on the MDA’s for the ‘70s so 


there’s some data there, but it’s not as 


complete as the other years; is that correct? 

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 MR. FALK: Yes. 


 MR. BUCHANAN: Okay. Well, that clarifies a 


lot of issues on question number 3. 


 DR. MAKHIJANI: When did they start wearing the 


lead aprons? 


 MR. FALK: I do not know. 


 DR. MAKHIJANI: So this -- Again, whenever 


you’ve got neutron to photon ratios I guess you 


-- you’re going to have this question. 


 MR. FALK: Yeah. 


 DR. MAKHIJANI: Presumably. 


 MS. MUNN: But it wasn’t the ‘50s and ‘60s -- 


 DR. MAKHIJANI: Yeah. Well --


 MS. MUNN: -- it was the --


 DR. MAKHIJANI: Right. 


 MR. FALK: It was transferred to the body 


counter also in 1970. It wasn’t a very well-


behaved year. 


 MR. GRIFFON: Hey, Ron, did the question we 


just discussed, the two questions, do they 


fully address any issues that are -- I just 


got the report from Joe that he forwarded me, 


and your report on the OTIB 50. Are there 


other issues in there that were not in this 


question? 

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 MR. FITZGERALD: Ron, just to clarify, you 


earlier indicated that these three were the 


ones that perhaps touched on some SEC 


significant concerns. I don’t -- I think 


there’s other perhaps questions, but they’re 


probably just more site profile related. 


 MR. BUCHANAN: Yes, that’s correct. These --


These three were -- were boiled down to be the 


possible SEC which I needed to address, you 


know; of course we did make a statement on 


that. But yeah, I think the rest of these 


(unintelligible) in OTIB for site profile that 


were TIB’s. I didn’t have a lot of question on 


that. It was so directly linked to NDRP. But 


I had to ask each questions on NDRP to fully 


evaluate OTIB. So no, I don’t think that 


they’re SEC. 


 MR. GRIFFON: Is there anything else on -- on 


comment 3 or are we closing in on the end here? 


 MR. BUCHANAN: I think that the -- that’s it 


for right now. 


 MR. GRIFFON: Do you want to go through the 


other 20 comments? 


 DR. WADE: Sadly, we’re close to the end. We 


were having such fun. 

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 MS. MUNN: Sadly indeed. 


 MR. GRIFFON: We’re at the end of our packing 


list here. 


 MR. FITZGERALD: You haven’t hung up, Mark. 


 MR. GRIFFON: I don’t think we have any sample 


DR’s at this point for Rocky or anything like 


that. 


 DR. ULSH: No. No, not yet. 


 MS. MUNN: We’re nearing the end of our energy 


level as well, Mark. 


 MR. GRIFFON: Right, right. It’s not only the 


microphones fading now, it’s the people. 


 MS. MUNN: True, true. 


 MR. GRIFFON: So I think it’s time to adjourn 


unless there’s any other issues here. 


 DR. WADE: No. Just with great thanks to -- to 


all participants. And it was a long day, but 


it was a productive day, and as I said, if 


other information comes available, please share 


with all involved, including the board, and 


then we’ll see --


 MR. GRIFFON: Did you put us on hold, Lew? 


 DR. WADE: What’s that? 


 MR. GRIFFON: Did you put us on hold? 


 DR. WADE: No. 

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 MS. MUNN: Somebody else did. 


 DR. WADE: Somebody else did but we can -- 


 MR. GRIFFON: We got music. 


 DR. WADE: That's fine. You can use that music 


to play us off the stage. 


 MR. GRIFFON: Well, I -- I will offer also to 


update the matrix again for our next meeting 


prior to -- prior to the next meeting. 


 DR. WADE: Wanda --


 MR. GRIFFON: I also would hope that -- don’t 


wait on me to update the matrix to -- to 


proceed on the action, because it could take a 


little while to sort these out and get them 


into a matrix format; but I will follow up on ­

-


 MS. MUNN: Thank you. You have all those items 


that can drop off now. 


 DR. WADE: Okay. I think we’re done. 

 MS. MUNN: We’ll see you in a couple weeks. 

 DR. WADE: See you soon. Be safe. 

(Whereupon, the working group meeting was 


adjourned at 4:30 p.m.) 

______________________________ 

259 

1 CERTIFICATE OF COURT REPORTER 


STATE OF GEORGIA 


COUNTY OF FULTON 


 I, Steven Ray Green, Certified Merit Court 


Reporter, do hereby certify that I reported the 


above and foregoing on the day of March 28, 


2006; and it is a true and accurate transcript 


of the testimony captioned herein. 


 I further certify that I am neither kin 


nor counsel to any of the parties herein, nor 


have any interest in the cause named herein. 


 WITNESS my hand and official seal this the 


3rd day of May, 2006. 


STEVEN RAY GREEN, CCR 


CERTIFIED MERIT COURT REPORTER 


CERTIFICATE NUMBER: A-2102